Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.
Compliance Requirement: L
Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late.
Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period).
Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance.
Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance.
Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: A/B
Condition: I noted that an indirect rate of 17.5% percent was charged to federal awards instead of the 10% rate approved in the grant awards.
Criteria: 2 CFR 200.414, Indirect Costs, require non-Federal entities to apply the negotiated indirect cost rate, or the de minimis rate of 10% of modified total direct costs (MTDC) if elected and applicable, consistently to all eligible federal awards.
Cause and effect: The application of the incorrect indirect cost rate has resulted in unallowable charges to the federal award.
Recommendation: I recommend management ensure that the proper indirect cost rate is properly applied in accordance with the Uniform Guidance and ensures that appropriate costs are charged to the awards consistent with their federally approved budgets.
Views of Responsible Officials: Upon conducting the FY21 audit, TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal budgets (approximately 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY22 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation.
Moving forward TAS will be billing the de minimus rate (10%) as a percentage, unless otherwise noted in the agreement.