Management appreciates the opportunity to respond to Finding 2025-001. The questioned cost relates to payment for CRE’s federally required financial audit for the year ended December 31, 2025. The costs of the audit were in fact liquidated by virtue of an audit engagement letter received. The audit ...
Management appreciates the opportunity to respond to Finding 2025-001. The questioned cost relates to payment for CRE’s federally required financial audit for the year ended December 31, 2025. The costs of the audit were in fact liquidated by virtue of an audit engagement letter received. The audit procedures addressed financial activity, finalyear expenditures, financial reporting, internal control, and compliance requirements associated with the five-year ACF award that concluded in 2025. The payment was not intended to support future program operations, future service delivery, or activities to be performed under a subsequent award period. Management respectfully requests that ACF evaluate the questioned cost based on the purpose of the expenditure, the benefit received by the federal award, and the documentation supporting the transaction. The audit was required because of the financial activity conducted under the completed ACF award. The audit tested costs incurred, funds drawn, financial reporting, internal control, and compliance obligations arising from that award. Management does not believe the cost provided a programmatic or administrative benefit to a later federal award. CRE charged the audit cost to the award that received the benefit of the audit services because management determined that award to be the appropriate cost objective. Charging the cost to a subsequent award solely because the audit work or payment occurred after the award end date would have resulted in a different federal award, and potentially a different federal agency, bearing the cost of audit procedures performed on activity attributable to the completed ACF award. Management acknowledges that the period-of-performance requirements are an important compliance consideration and does not assert that the allocation rationale alone overrides those requirements. However, management believes the facts and circumstances distinguish this transaction from an advance payment or prepayment for future program services. The audit was completed, the amount was supported by documentation, the cost was not charged to another federal award, and the Federal Government received the intended financial oversight and compliance benefit associated with the completed award. Accordingly, management respectfully requests that ACF consider allowing the portion of the audit cost that is reasonably attributable to the completed ACF award. If ACF determines that a portion of the cost is not allowable based on the period of performance, management requests that the final determination clearly distinguish any disallowance based on timing from the allowability, reasonableness, allocability, and documentation of the audit service itself. Management also requests that the final finding accurately describe the nature of the questioned cost as a federally required financial audit of activity for the year ended December 31, 2025. The current characterization of the payment as a prepayment to a third party for services to be provided in 2026 does not fully describe the purpose of the expenditure and may imply that the payment supported 2026 program activity, which management believes is inconsistent with the underlying purpose and benefit of the audit services. CRE has procedures to review both the period in which contracted services are performed and the award that receives the benefit of those services. As a corrective action, for future grants approaching expiration, CRE will obtain written guidance from the awarding agency before charging audit, closeout, or other post-award professional service costs to an expiring award. CRE will also document the basis for any allocation decision, including the applicable award, period of performance, benefit received, and supporting documentation retained for audit review.