Finding 2023-001
Finding: Significant deficiency in Internal Control over Compliance (Allowable Costs)
Corrective Action Plan:
CARS management has reviewed the audit findings related to unallowable severance costs, as well as the governance of the estimated and applied fringe rate across all proj...
Finding 2023-001
Finding: Significant deficiency in Internal Control over Compliance (Allowable Costs)
Corrective Action Plan:
CARS management has reviewed the audit findings related to unallowable severance costs, as well as the governance of the estimated and applied fringe rate across all projects. It is the opinion of the auditor that projects were overburdened by severance costs that were unallowable due to being in excess of the company’s established policy for calculating severance. However, per guidance at 2 CFR 200.431, as identified in the criteria section of the report verbiage, severance pay is allowable when required by one, or more, of the following: 1. law, 2. employment agreement, 3. established policy that constitutes an implied agreement, and/or 4. circumstances of the particular employment.
It is the opinion of CARS management that claimed severance costs are allowable based on two of the four criteria: 1. Circumstances of employment, and 2. An established policy that was, in effect, an agreement with the employees. Our organization had a written severance policy at the time these costs were incurred. Although all claimed severance costs were based on CARS’ current policy, we have accepted the terms of the audit results for the sole purpose of concluding the audit process.
CARS does concur that the current written accounting policy needs to be updated to more accurately reflect and summarize the procedures in place. We are continuing to update written policy verbiage to ensure its alignment with the implied policy that had developed as a result of hiring practices across California’s protected classes. As a result of this audit report, CARS will continue to monitor and assess the need for additional procedures and incorporate changes into the indirect rate reporting processes and written policy as necessary.
Anticipated Completion Date:
CARS will have its severance policy updated by the end of the fourth quarter of 2024. CARS has updated its procedures to review and monitor the fringe rate and ensure all costs allocated to the final projects are allocable, reasonable in amount, and allowable per policy, contract terms, and regulations to include the documentation of the fringe rate review beginning in October 2024.
CARS Contact Person Responsible for Corrective Action: Kerrilyn Nakai