Audit 407180

2024-001: Improper Billing on Cost Reimbursement Program Type of Finding: Material Noncompliance, Material Weakness in Internal Control over Financial Reporting, and Material Weakness in Internal Control over Compliance Program: U.S. Department of Defense, ALN 12.UKN – Guam – Navy AAFB NBG & USMC Criteria: Subpart E of the Uniform Guidance, Section 200.400(g) states that the recipient or subrecipient must not earn or keep any profit resulting from Federal financial assistance unless explicitly authorized by the terms and conditions of the Federal award. Condition: The Organization invoiced the Federal program based on an estimated rate that was not supported by expected direct and indirect costs allocable to the program. Cause: The Organization does not have proper controls in place to ensure that program invoices are properly supported by direct costs plus the applicable allocation of indirect costs. Effect: The Federal program was invoiced for amounts in excess of actual costs incurred. Questioned Costs: Questioned costs totaled $1,561,349 and were computed as the total amount billed less the actual expenditures charged to the program. Context: During the year under audit, we noted that invoices were materially higher than the actual costs recorded for the invoice period. This would have been discovered and corrected prior to the audit had a proper review system been followed by individuals knowledgeable of the provisions of the Uniform Guidance, including members of the Board of Directors in their oversight capacity. Repeat Finding: No Recommendation: Management, with direction from and oversight by the Board of Directors, should take steps to make sure that actual billings do not exceed expenditures, inclusive of indirect costs allocable to the program. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. The Organization has addressed its corrective action plan in a separately issued letter.