Audit 372774

CFR § 200.404 Reasonable Costs Finding Number: 2023-003 Assistance Listing Number and Title: AL # 84.425 Education Stabilization Fund – Elementary and Secondary Education Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Education Compliance Requirement: 2 CFR § 200.404 Pass-Through Entity: Ohio Department of Education & Workforce Repeat Finding from Prior Audit? No A-Noncompliance and Material Weakness 2 CFR § 200.404 states that a cost is reasonable if it does not exceed an amount that a prudent person would incur under the circumstances prevailing when the decision was made to incur the cost. In determining the reasonableness of a given cost, consideration must be given to the following: (a) Whether the cost is generally recognized as ordinary and necessary for the recipient's or subrecipient's operation or the proper and efficient performance of the Federal award; (b) The restraints or requirements imposed by such factors as sound business practices; arm's-length bargaining; Federal, State, local, tribal, and other laws and regulations; and terms and conditions of the Federal award; (c) Market prices for comparable costs for the geographic area; (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the recipient or subrecipient, its employees, its students or membership (if applicable), the public at large, and the Federal Government; and (e) Whether the cost represents a deviation from the recipient's or subrecipient's established written policies and procedures for incurring costs. The District used Federal American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) grant funding in the amount of $8,648 for airfare for three employees to attend a three-day professional development conference in Rwanda, Africa. Because there were options for professional development conferences with similar content that did not require overseas travel, this expenditure does not meet the prudent person test and the cost of the airfare is deemed excessive in relation to the guidelines above. Furthermore, the use of Federal funding for unallowable expenditure such as this indicates a lack of effective controls over compliance with Federal Allowable Cost/Cost Principle requirements. District management should review all grant award documents in order to execute policies and procedures which help ensure compliance with grant requirements including reasonableness of all expenditures.