Views of Responsible Officials and Planned Corrective Actions: LHCA's methodology for qualifying laboratory and affiliated organization expenses as industry in-kind contribution was developed in direct consultation with FAS program officials in June 2023. As documented in LHCA's written summary of t...
Views of Responsible Officials and Planned Corrective Actions: LHCA's methodology for qualifying laboratory and affiliated organization expenses as industry in-kind contribution was developed in direct consultation with FAS program officials in June 2023. As documented in LHCA's written summary of that meeting, transmitted to senior FAS program and operations officials including the FMD program officer and acknowledged without objection, FAS validated the eligibility of research, marketing, policy, and technical expenses funded through industry funds, focused on target markets, and connected to UES activities. LHCA was acting on direct FAS guidance, not making unsupported determinations, and that documentation is available for the auditor's review. The revenue figures that appeared in LHCA's contribution documentation served as an allocation methodology, a proportional basis for determining what share of multi-purpose expenses relates to export promotion, not as the contribution itself. The actual contribution claimed consisted of underlying expenses allocated using that methodology. LHCA acknowledges that this methodology was not clearly labeled in the documentation provided to auditors, and will revise its documentation format to clearly distinguish the allocation calculation from the contribution amount claimed, ensuring the two are not conflated in future reviews. LHCA will formalize its contribution tracking procedures with a written policy document that defines eligible activities consistent with FAS guidance, specifies the allocation methodology and its basis, and requires that all claimed contribution be supported by verifiable expense documentation consistent with the hierarchy established in FMD §1484.33(f) and the cost principles in 2 CFR Part 200 Subpart E. A documented review and approval process will be implemented to ensure contribution amounts are accurate, allowable, and properly supported prior to submission.