Management agrees with the finding and is implementing the accompanying corrective action plan.
Views of Responsible Officials:
Jacy Hyde, Executive Director
Joel Rusco, Chief Financial and Administrative Officer
Jessica Martinez, Deputy Director
Contact Person:
Jessica Martinez, Deputy Director
Jo...
Management agrees with the finding and is implementing the accompanying corrective action plan.
Views of Responsible Officials:
Jacy Hyde, Executive Director
Joel Rusco, Chief Financial and Administrative Officer
Jessica Martinez, Deputy Director
Contact Person:
Jessica Martinez, Deputy Director
Joel Rusco, Chief Financial and Administrative Officer
Corrective Action Plan:
In response to FY21 Corrective Action Plan, CFSC implemented an updated Reporting Policy in June 2024 to strengthen internal controls prior to review and submission of invoices and drawdown/payment requests to funders. To ensure further compliance with 2 CFR 200.414(c), 2 CFR 200.403(d), and 2 CFR 200.302(b)(3), CFSC will implement the following corrective actions:
1.Verification of Indirect Cost Rate Before Submission:
a.CFSC will require that all invoices, including indirect costs, be reviewed by the CFAO to confirm that the rate used is in accordance with an approved provisional or final NICRA agreement.
b.Any invoice for federal funding lacking an approved indirect cost rate will be flagged and returned for correction before submission.
2.Pre-Submission Approval Process for Invoicing Indirect Costs:
a.All invoice requests containing indirect costs must be reviewed and approved by the CFAO prior to submission.
b.The Finance Department will verify and document that the rate applied is consistent across all federal awards and matches the NICRA.
3.Indirect Cost Rate Agreement Tracking & Documentation:
a.CFSC Finance will establish an Indirect Cost Rate Agreement tracker to ensure that:
i.All provisional and final indirect cost rate agreements are maintained on file.
ii.Indirect cost rates used on invoices are consistently aligned with approved agreements.
4.Quarterly Internal Audits of Indirect Cost Rate Compliance:
CFSC Finance Department will conduct quarterly reviews of a sample of drawdown/payment request invoices to confirm:
a.The correct indirect cost rate was applied
b.The rate was consistently applied across all federal awards
Anticipated Completion Date:
These corrective actions will be fully implemented by the end of Quarter 2 of FY25