Audit 4249

2022-002 – ACTIVITIES ALLOWED OR UNALLOWED Federal Program: Shuttered Venue Operators Grant Federal Agency: Small Business Administration Assistance Listing Number: 59.075 Grant Award Number and Year: SBAHQ21SVO11340, 8/5/2021 – 8/4/2022 Criteria: The Shuttered Venue Operators Grant (SVOG) award documents include provisions that state cost principles must follow 2 CFR 200 Cost Principles, and Audit Requirements for Federal Awards, which sets the rules for allowable costs for federal awards. In accordance with 2 CFR 200.442, fundraising costs are not allowable. In addition, the U.S. Small Business Administration (SBA) issued Post-Award Frequently Asked Questions for the SVOG on February 16, 2022, which further clarified that fundraising is not an allowable cost for SVOG awards. Condition: Our testing identified that the Foundation’s detail of expenditures reimbursed under its SVOG award included fundraising expenses. After being made aware of these unallowable costs, the Foundation was able to identify additional allowable costs which could be substituted for the unallowable costs initially claimed for reimbursement. Therefore, there was no adjustment or refund needed for the SVOG awards claimed by the Foundation. Questioned Costs: No questioned costs as the Foundation was able to identify additional allowable costs it had incurred as described above. Cause: Foundation personnel responsible for administering this award and ensuring compliance were not familiar with the allowable cost principles of 2 CFR 200. Effect: The initial supporting calculations used to develop the required reports submitted to the SBA included unallowable costs. There was no net effect on the reports submitted, after correction of the supporting calculations. Recommendation: We recommend the Foundation ensure that personnel who are responsible for administering and overseeing new federal award activity be sufficiently knowledgeable about such federal programs, including reading the allowable costs principles referred to in the grant agreements and reviewing for subsequent guidance released by awarding agencies. Foundation’s Corrective Action Plan: To ensure compliance moving forward with federal grant opportunities, the Foundation will require staff responsible for compliance, to review all program requirements and monitor for subsequently released guidance issued by the awarding agencies.

2022-002 – ACTIVITIES ALLOWED OR UNALLOWED Federal Program: Shuttered Venue Operators Grant Federal Agency: Small Business Administration Assistance Listing Number: 59.075 Grant Award Number and Year: SBAHQ21SVO11340, 8/5/2021 – 8/4/2022 Criteria: The Shuttered Venue Operators Grant (SVOG) award documents include provisions that state cost principles must follow 2 CFR 200 Cost Principles, and Audit Requirements for Federal Awards, which sets the rules for allowable costs for federal awards. In accordance with 2 CFR 200.442, fundraising costs are not allowable. In addition, the U.S. Small Business Administration (SBA) issued Post-Award Frequently Asked Questions for the SVOG on February 16, 2022, which further clarified that fundraising is not an allowable cost for SVOG awards. Condition: Our testing identified that the Foundation’s detail of expenditures reimbursed under its SVOG award included fundraising expenses. After being made aware of these unallowable costs, the Foundation was able to identify additional allowable costs which could be substituted for the unallowable costs initially claimed for reimbursement. Therefore, there was no adjustment or refund needed for the SVOG awards claimed by the Foundation. Questioned Costs: No questioned costs as the Foundation was able to identify additional allowable costs it had incurred as described above. Cause: Foundation personnel responsible for administering this award and ensuring compliance were not familiar with the allowable cost principles of 2 CFR 200. Effect: The initial supporting calculations used to develop the required reports submitted to the SBA included unallowable costs. There was no net effect on the reports submitted, after correction of the supporting calculations. Recommendation: We recommend the Foundation ensure that personnel who are responsible for administering and overseeing new federal award activity be sufficiently knowledgeable about such federal programs, including reading the allowable costs principles referred to in the grant agreements and reviewing for subsequent guidance released by awarding agencies. Foundation’s Corrective Action Plan: To ensure compliance moving forward with federal grant opportunities, the Foundation will require staff responsible for compliance, to review all program requirements and monitor for subsequently released guidance issued by the awarding agencies.