Cluster name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award numbers and years: DI21-002286, April 1, 2022 through June 30, 2024; Alert 23-001, July 1, 2023 through June 30, 2024; Alert 23-003, July 1, 2023 through June 30, 2024; Alert 24-002, July 1, 2023 through May 31, 2024 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Questioned costs: N/A Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Pass-through grantors: Arizona Criminal Justice Commission, City of Tucson, Arizona Housing Coalition, and Arizona Department of Public Safety Questioned costs: N/A Assistance Listings number and name: 97.024 COVID-19 - Emergency Food and Shelter National Board Program Award numbers and years: 027200-048, November 1, 2021 through December 30, 2024; 027200-056, April 1, 2023 through February 29, 2024; 23*115, March 1, 2023 through February 29, 2024; 23*154, April 1, 2023 through February 29, 2024 Federal agency: U.S. Department of Homeland Security Pass-through grantor: United Way EFSP Questioned costs: $347,345 Assistance Listings number and name: 97.141 Shelter and Services Program Award number and year: 24*039, March 1, 2023 through September 30, 2025 Federal agency: U.S. Department of Homeland Security Questioned costs: N/A Compliance requirement: Subrecipient monitoring Total questioned costs: $347,345 Condition—The County’s Grants Management and Innovation Department (Department) awarded over $29 million to 27 subrecipients during fiscal year 2024, or 29% of the County’s total federal expenditures for the federal programs shown in Table 1 below, but did not perform all the required monitoring of its subrecipients’ activities or compliance with award terms and program requirements. Table 1 Summary of subrecipients by federal program Fiscal year 2024 Federal program name Subrecipient information Total number Number tested Total awards Total federal expenditures Subrecipient awards as a percentage of total federal expenditures Workforce Innovation and Opportunity Act (WIOA) Cluster 4 4 $ 568,095 $12,253,972 4.6% Coronavirus State and Local Fiscal Recovery Funds (SLFRF) 17 7 17,241,445 56,862,338 30.3% Emergency Food and Shelter National Board Program (EFS) 4 4 7,810,673 22,622,229 34.5% Shelter and Services Program (SSP) 2 2 3,560,449 8,172,063 43.5% Total 27 17 $29,180,662 $99,910,602 29.2% While the Department performed some monitoring procedures during the year, those procedures were not sufficient to evaluate its subrecipients’ use of program monies in accordance with the award terms, program requirements, and federal regulations. Specifically, contrary to federal regulations, the Department did not perform the following required monitoring procedures: • Perform monitoring activities based on risk assessments performed—The Department did not perform monitoring activities based on risk assessments performed. Specifically, the Department’s risk assessment procedures identified 7 high-risk and 4 moderate-risk subrecipients, but it did not modify its monitoring activities to address the risks identified. Additional monitoring activities could include providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures like reviewing the subrecipient’s policies and procedures obtained to ensure the subrecipients complied with award terms, program requirements, and federal regulations. • Document monitoring procedures, results, and actions taken—For 4 of 4 WIOA subrecipients, 7 of 7 SLFRF subrecipients, 3 of 4 EFS subrecipients, and 1 of 2 SSP subrecipients we tested, while the Department completed and maintained a checklist of subrecipient monitoring procedures, it did not document monitoring results or Department actions taken for these subrecipients based on the checklist results. • Verify subrecipient single audits were conducted timely—The Department did not verify whether 1 of its 4 WIOA subrecipients had a single audit performed. Effect—The Department’s failure to perform required monitoring contributed to $347,345 of misspent EFS program monies that the Department may be required to return to the federal agency in accordance with federal requirements.1 Specifically, the Department’s not reviewing subrecipient procurement policies and procedures aided in allowing 1 EFS subrecipient to render services for which conflicts of interest existed. Specifically, the EFS subrecipient, Catholic Community Services (CCS), began having laundry services provided by a vendor, Amado Laundry, in April 2023, for which it then self-reported to the County a conflict-of-interest violation in May 2024. This violation was a result of a CCS employee forming a vendor relationship with Amado Laundry, which was owned by the employee’s mother. After the Department’s management was made aware of the conflict of interest, they performed monitoring procedures over CCS and identified noncompliance with federal procurement guidelines totaling $347,345, including determining that Amado Laundry charged a rate double the average rates charged by competitors. The County issued a management letter to CCS on September 27, 2024, communicating a conflict-of-interest finding and a procurement standards finding. The conflict-of-interest finding required CCS to develop new, written procurement-related conflict-of-interest procedures in compliance with federal regulations and to create and maintain an ongoing training program related to these federally compliant conflict-of-interest procedures for employees. Further, there is an increased risk that $29 million of program monies the Department awarded to subrecipients may not be spent in accordance with the award terms, program requirements, and federal regulations. If monies are spent inconsistent with program requirements, those who intended to benefit from the program may not receive all the services or other benefits they otherwise would have received. Also, the Department’s not verifying subrecipient single audits were conducted may result in the Department’s not following up on and ensuring corrective action is taken on audit findings that could potentially affect the program and/or issue management decisions for audit findings pertaining to the federal award. Finally, the County is at risk that this finding applies to other federal programs it administers. Cause—The Department’s management reported that they did not always follow County policies and procedures and only performed limited procedures because their subrecipient monitoring policies and procedures were outdated, the number of subrecipients increased significantly during the fiscal year, and they did not have sufficient staff to monitor all subrecipients. The Department’s management also reported that it prioritized transitioning to a new enterprise resource planning (ERP) system rather than monitoring all subrecipients. Further, the County’s policies lacked requirements to perform monitoring activities based on risk assessments performed and to review subrecipients’ policies and procedures to ensure the subrecipients complied with award terms, program requirements, and federal regulations. Criteria—Federal regulation requires the County to monitor subrecipients, which includes required monitoring procedures for (2 CFR §200.332): • Assessing the risk of each subrecipient’s noncompliance and performing monitoring activities based on those risk assessments, such as providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures. • Reviewing financial and performance reports. • Verifying single audits were conducted timely. • Following up on and ensuring corrective action is taken on audit findings that could potentially affect the program. • Issuing a management decision for audit findings pertaining to the federal award. In addition, County policies require the County to: • Assess subrecipient risk and establish a monitoring plan and perform monitoring procedures at least every 2 years, including verification of internal controls.2,3 • Review the Federal Audit Clearinghouse at least quarterly to review subrecipient single audits and issue management decision letters, as necessary.2 • Maintain documentation of monitoring procedures, including the monitoring procedure’s results and any Department actions taken.3 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the County— 1. Perform required monitoring of its subrecipients and their compliance with the award terms, program requirements, and federal regulations. 2. Follow its established policies and procedures for performing and documenting monitoring reviews of subrecipients to: a. Maintain documentation of monitoring procedures demonstrating they were performed, including the monitoring procedures’ results and any Department actions taken, if appropriate. b. Verify subrecipients receive timely single audits, follow up on and ensure that corrective action is taken on audit findings that could potentially affect the program, and issue management decisions for audit findings pertaining to the federal award. 3. Update its policies and procedures to include: a. A process to determine the appropriate monitoring activities to perform based on subrecipient risk assessments performed, such as providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures. b. Review subrecipients’ policies and procedures, including procurement processes, to ensure the subrecipients complied with award terms, program requirements, and federal regulations. 4. Prioritize and allocate sufficient resources, such as staffing, to comply with the award terms, program requirements, federal regulations, and its updated policies, and designate an individual(s) to perform necessary subrecipient-monitoring procedures. 5. Work with U.S. Department of Homeland Security to determine if it will require the Department to reimburse $347,345 in questioned costs. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2022-101 and was initially reported in fiscal year 2022. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 2 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-04: Subrecipient Risk Assessment / Management Decisions. 3 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-28: Subrecipient Monitoring.
Cluster name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award numbers and years: DI21-002286, April 1, 2022 through June 30, 2024; Alert 23-001, July 1, 2023 through June 30, 2024; Alert 23-003, July 1, 2023 through June 30, 2024; Alert 24-002, July 1, 2023 through May 31, 2024 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Questioned costs: N/A Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Pass-through grantors: Arizona Criminal Justice Commission, City of Tucson, Arizona Housing Coalition, and Arizona Department of Public Safety Questioned costs: N/A Assistance Listings number and name: 97.024 COVID-19 - Emergency Food and Shelter National Board Program Award numbers and years: 027200-048, November 1, 2021 through December 30, 2024; 027200-056, April 1, 2023 through February 29, 2024; 23*115, March 1, 2023 through February 29, 2024; 23*154, April 1, 2023 through February 29, 2024 Federal agency: U.S. Department of Homeland Security Pass-through grantor: United Way EFSP Questioned costs: $347,345 Assistance Listings number and name: 97.141 Shelter and Services Program Award number and year: 24*039, March 1, 2023 through September 30, 2025 Federal agency: U.S. Department of Homeland Security Questioned costs: N/A Compliance requirement: Subrecipient monitoring Total questioned costs: $347,345 Condition—The County’s Grants Management and Innovation Department (Department) awarded over $29 million to 27 subrecipients during fiscal year 2024, or 29% of the County’s total federal expenditures for the federal programs shown in Table 1 below, but did not perform all the required monitoring of its subrecipients’ activities or compliance with award terms and program requirements. Table 1 Summary of subrecipients by federal program Fiscal year 2024 Federal program name Subrecipient information Total number Number tested Total awards Total federal expenditures Subrecipient awards as a percentage of total federal expenditures Workforce Innovation and Opportunity Act (WIOA) Cluster 4 4 $ 568,095 $12,253,972 4.6% Coronavirus State and Local Fiscal Recovery Funds (SLFRF) 17 7 17,241,445 56,862,338 30.3% Emergency Food and Shelter National Board Program (EFS) 4 4 7,810,673 22,622,229 34.5% Shelter and Services Program (SSP) 2 2 3,560,449 8,172,063 43.5% Total 27 17 $29,180,662 $99,910,602 29.2% While the Department performed some monitoring procedures during the year, those procedures were not sufficient to evaluate its subrecipients’ use of program monies in accordance with the award terms, program requirements, and federal regulations. Specifically, contrary to federal regulations, the Department did not perform the following required monitoring procedures: • Perform monitoring activities based on risk assessments performed—The Department did not perform monitoring activities based on risk assessments performed. Specifically, the Department’s risk assessment procedures identified 7 high-risk and 4 moderate-risk subrecipients, but it did not modify its monitoring activities to address the risks identified. Additional monitoring activities could include providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures like reviewing the subrecipient’s policies and procedures obtained to ensure the subrecipients complied with award terms, program requirements, and federal regulations. • Document monitoring procedures, results, and actions taken—For 4 of 4 WIOA subrecipients, 7 of 7 SLFRF subrecipients, 3 of 4 EFS subrecipients, and 1 of 2 SSP subrecipients we tested, while the Department completed and maintained a checklist of subrecipient monitoring procedures, it did not document monitoring results or Department actions taken for these subrecipients based on the checklist results. • Verify subrecipient single audits were conducted timely—The Department did not verify whether 1 of its 4 WIOA subrecipients had a single audit performed. Effect—The Department’s failure to perform required monitoring contributed to $347,345 of misspent EFS program monies that the Department may be required to return to the federal agency in accordance with federal requirements.1 Specifically, the Department’s not reviewing subrecipient procurement policies and procedures aided in allowing 1 EFS subrecipient to render services for which conflicts of interest existed. Specifically, the EFS subrecipient, Catholic Community Services (CCS), began having laundry services provided by a vendor, Amado Laundry, in April 2023, for which it then self-reported to the County a conflict-of-interest violation in May 2024. This violation was a result of a CCS employee forming a vendor relationship with Amado Laundry, which was owned by the employee’s mother. After the Department’s management was made aware of the conflict of interest, they performed monitoring procedures over CCS and identified noncompliance with federal procurement guidelines totaling $347,345, including determining that Amado Laundry charged a rate double the average rates charged by competitors. The County issued a management letter to CCS on September 27, 2024, communicating a conflict-of-interest finding and a procurement standards finding. The conflict-of-interest finding required CCS to develop new, written procurement-related conflict-of-interest procedures in compliance with federal regulations and to create and maintain an ongoing training program related to these federally compliant conflict-of-interest procedures for employees. Further, there is an increased risk that $29 million of program monies the Department awarded to subrecipients may not be spent in accordance with the award terms, program requirements, and federal regulations. If monies are spent inconsistent with program requirements, those who intended to benefit from the program may not receive all the services or other benefits they otherwise would have received. Also, the Department’s not verifying subrecipient single audits were conducted may result in the Department’s not following up on and ensuring corrective action is taken on audit findings that could potentially affect the program and/or issue management decisions for audit findings pertaining to the federal award. Finally, the County is at risk that this finding applies to other federal programs it administers. Cause—The Department’s management reported that they did not always follow County policies and procedures and only performed limited procedures because their subrecipient monitoring policies and procedures were outdated, the number of subrecipients increased significantly during the fiscal year, and they did not have sufficient staff to monitor all subrecipients. The Department’s management also reported that it prioritized transitioning to a new enterprise resource planning (ERP) system rather than monitoring all subrecipients. Further, the County’s policies lacked requirements to perform monitoring activities based on risk assessments performed and to review subrecipients’ policies and procedures to ensure the subrecipients complied with award terms, program requirements, and federal regulations. Criteria—Federal regulation requires the County to monitor subrecipients, which includes required monitoring procedures for (2 CFR §200.332): • Assessing the risk of each subrecipient’s noncompliance and performing monitoring activities based on those risk assessments, such as providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures. • Reviewing financial and performance reports. • Verifying single audits were conducted timely. • Following up on and ensuring corrective action is taken on audit findings that could potentially affect the program. • Issuing a management decision for audit findings pertaining to the federal award. In addition, County policies require the County to: • Assess subrecipient risk and establish a monitoring plan and perform monitoring procedures at least every 2 years, including verification of internal controls.2,3 • Review the Federal Audit Clearinghouse at least quarterly to review subrecipient single audits and issue management decision letters, as necessary.2 • Maintain documentation of monitoring procedures, including the monitoring procedure’s results and any Department actions taken.3 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the County— 1. Perform required monitoring of its subrecipients and their compliance with the award terms, program requirements, and federal regulations. 2. Follow its established policies and procedures for performing and documenting monitoring reviews of subrecipients to: a. Maintain documentation of monitoring procedures demonstrating they were performed, including the monitoring procedures’ results and any Department actions taken, if appropriate. b. Verify subrecipients receive timely single audits, follow up on and ensure that corrective action is taken on audit findings that could potentially affect the program, and issue management decisions for audit findings pertaining to the federal award. 3. Update its policies and procedures to include: a. A process to determine the appropriate monitoring activities to perform based on subrecipient risk assessments performed, such as providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures. b. Review subrecipients’ policies and procedures, including procurement processes, to ensure the subrecipients complied with award terms, program requirements, and federal regulations. 4. Prioritize and allocate sufficient resources, such as staffing, to comply with the award terms, program requirements, federal regulations, and its updated policies, and designate an individual(s) to perform necessary subrecipient-monitoring procedures. 5. Work with U.S. Department of Homeland Security to determine if it will require the Department to reimburse $347,345 in questioned costs. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2022-101 and was initially reported in fiscal year 2022. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 2 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-04: Subrecipient Risk Assessment / Management Decisions. 3 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-28: Subrecipient Monitoring.
Cluster name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award numbers and years: DI21-002286, April 1, 2022 through June 30, 2024; Alert 23-001, July 1, 2023 through June 30, 2024; Alert 23-003, July 1, 2023 through June 30, 2024; Alert 24-002, July 1, 2023 through May 31, 2024 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Questioned costs: N/A Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Pass-through grantors: Arizona Criminal Justice Commission, City of Tucson, Arizona Housing Coalition, and Arizona Department of Public Safety Questioned costs: N/A Assistance Listings number and name: 97.024 COVID-19 - Emergency Food and Shelter National Board Program Award numbers and years: 027200-048, November 1, 2021 through December 30, 2024; 027200-056, April 1, 2023 through February 29, 2024; 23*115, March 1, 2023 through February 29, 2024; 23*154, April 1, 2023 through February 29, 2024 Federal agency: U.S. Department of Homeland Security Pass-through grantor: United Way EFSP Questioned costs: $347,345 Assistance Listings number and name: 97.141 Shelter and Services Program Award number and year: 24*039, March 1, 2023 through September 30, 2025 Federal agency: U.S. Department of Homeland Security Questioned costs: N/A Compliance requirement: Subrecipient monitoring Total questioned costs: $347,345 Condition—The County’s Grants Management and Innovation Department (Department) awarded over $29 million to 27 subrecipients during fiscal year 2024, or 29% of the County’s total federal expenditures for the federal programs shown in Table 1 below, but did not perform all the required monitoring of its subrecipients’ activities or compliance with award terms and program requirements. Table 1 Summary of subrecipients by federal program Fiscal year 2024 Federal program name Subrecipient information Total number Number tested Total awards Total federal expenditures Subrecipient awards as a percentage of total federal expenditures Workforce Innovation and Opportunity Act (WIOA) Cluster 4 4 $ 568,095 $12,253,972 4.6% Coronavirus State and Local Fiscal Recovery Funds (SLFRF) 17 7 17,241,445 56,862,338 30.3% Emergency Food and Shelter National Board Program (EFS) 4 4 7,810,673 22,622,229 34.5% Shelter and Services Program (SSP) 2 2 3,560,449 8,172,063 43.5% Total 27 17 $29,180,662 $99,910,602 29.2% While the Department performed some monitoring procedures during the year, those procedures were not sufficient to evaluate its subrecipients’ use of program monies in accordance with the award terms, program requirements, and federal regulations. Specifically, contrary to federal regulations, the Department did not perform the following required monitoring procedures: • Perform monitoring activities based on risk assessments performed—The Department did not perform monitoring activities based on risk assessments performed. Specifically, the Department’s risk assessment procedures identified 7 high-risk and 4 moderate-risk subrecipients, but it did not modify its monitoring activities to address the risks identified. Additional monitoring activities could include providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures like reviewing the subrecipient’s policies and procedures obtained to ensure the subrecipients complied with award terms, program requirements, and federal regulations. • Document monitoring procedures, results, and actions taken—For 4 of 4 WIOA subrecipients, 7 of 7 SLFRF subrecipients, 3 of 4 EFS subrecipients, and 1 of 2 SSP subrecipients we tested, while the Department completed and maintained a checklist of subrecipient monitoring procedures, it did not document monitoring results or Department actions taken for these subrecipients based on the checklist results. • Verify subrecipient single audits were conducted timely—The Department did not verify whether 1 of its 4 WIOA subrecipients had a single audit performed. Effect—The Department’s failure to perform required monitoring contributed to $347,345 of misspent EFS program monies that the Department may be required to return to the federal agency in accordance with federal requirements.1 Specifically, the Department’s not reviewing subrecipient procurement policies and procedures aided in allowing 1 EFS subrecipient to render services for which conflicts of interest existed. Specifically, the EFS subrecipient, Catholic Community Services (CCS), began having laundry services provided by a vendor, Amado Laundry, in April 2023, for which it then self-reported to the County a conflict-of-interest violation in May 2024. This violation was a result of a CCS employee forming a vendor relationship with Amado Laundry, which was owned by the employee’s mother. After the Department’s management was made aware of the conflict of interest, they performed monitoring procedures over CCS and identified noncompliance with federal procurement guidelines totaling $347,345, including determining that Amado Laundry charged a rate double the average rates charged by competitors. The County issued a management letter to CCS on September 27, 2024, communicating a conflict-of-interest finding and a procurement standards finding. The conflict-of-interest finding required CCS to develop new, written procurement-related conflict-of-interest procedures in compliance with federal regulations and to create and maintain an ongoing training program related to these federally compliant conflict-of-interest procedures for employees. Further, there is an increased risk that $29 million of program monies the Department awarded to subrecipients may not be spent in accordance with the award terms, program requirements, and federal regulations. If monies are spent inconsistent with program requirements, those who intended to benefit from the program may not receive all the services or other benefits they otherwise would have received. Also, the Department’s not verifying subrecipient single audits were conducted may result in the Department’s not following up on and ensuring corrective action is taken on audit findings that could potentially affect the program and/or issue management decisions for audit findings pertaining to the federal award. Finally, the County is at risk that this finding applies to other federal programs it administers. Cause—The Department’s management reported that they did not always follow County policies and procedures and only performed limited procedures because their subrecipient monitoring policies and procedures were outdated, the number of subrecipients increased significantly during the fiscal year, and they did not have sufficient staff to monitor all subrecipients. The Department’s management also reported that it prioritized transitioning to a new enterprise resource planning (ERP) system rather than monitoring all subrecipients. Further, the County’s policies lacked requirements to perform monitoring activities based on risk assessments performed and to review subrecipients’ policies and procedures to ensure the subrecipients complied with award terms, program requirements, and federal regulations. Criteria—Federal regulation requires the County to monitor subrecipients, which includes required monitoring procedures for (2 CFR §200.332): • Assessing the risk of each subrecipient’s noncompliance and performing monitoring activities based on those risk assessments, such as providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures. • Reviewing financial and performance reports. • Verifying single audits were conducted timely. • Following up on and ensuring corrective action is taken on audit findings that could potentially affect the program. • Issuing a management decision for audit findings pertaining to the federal award. In addition, County policies require the County to: • Assess subrecipient risk and establish a monitoring plan and perform monitoring procedures at least every 2 years, including verification of internal controls.2,3 • Review the Federal Audit Clearinghouse at least quarterly to review subrecipient single audits and issue management decision letters, as necessary.2 • Maintain documentation of monitoring procedures, including the monitoring procedure’s results and any Department actions taken.3 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the County— 1. Perform required monitoring of its subrecipients and their compliance with the award terms, program requirements, and federal regulations. 2. Follow its established policies and procedures for performing and documenting monitoring reviews of subrecipients to: a. Maintain documentation of monitoring procedures demonstrating they were performed, including the monitoring procedures’ results and any Department actions taken, if appropriate. b. Verify subrecipients receive timely single audits, follow up on and ensure that corrective action is taken on audit findings that could potentially affect the program, and issue management decisions for audit findings pertaining to the federal award. 3. Update its policies and procedures to include: a. A process to determine the appropriate monitoring activities to perform based on subrecipient risk assessments performed, such as providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures. b. Review subrecipients’ policies and procedures, including procurement processes, to ensure the subrecipients complied with award terms, program requirements, and federal regulations. 4. Prioritize and allocate sufficient resources, such as staffing, to comply with the award terms, program requirements, federal regulations, and its updated policies, and designate an individual(s) to perform necessary subrecipient-monitoring procedures. 5. Work with U.S. Department of Homeland Security to determine if it will require the Department to reimburse $347,345 in questioned costs. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2022-101 and was initially reported in fiscal year 2022. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 2 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-04: Subrecipient Risk Assessment / Management Decisions. 3 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-28: Subrecipient Monitoring.
Assistance Listings number and name: 21.032 COVID-19 - Local and Tribal Consistency Fund Award number and year: 1505-0276, October 20, 2022 through March 31, 2023 Federal agency: U.S. Department of the Treasury Assistance Listings number and name: 97.141 Shelter and Services Program Award number and year: 24*039, March 1, 2023 through September 30, 2025 Federal agency: U.S. Department of Homeland Security Compliance requirement: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulation, the County’s Grants Management and Innovation Department (Department) did not develop, document, or implement internal control procedures to monitor compliance with the programs’ reporting requirements. Specifically, for 5 of 7 federal program reports we tested, the Department did not perform an independent review and approval of reports prior to submitting them to the federal grantor to ensure the reported expenditures were accurate, agreed to the County’s records, and contained only allowable expenses, as follows: • 1 annual obligation and expenditure report for the Local and Tribal Consistency Fund (LTCF) totaling $7,924,031. • 3 quarterly financial reports and 3 quarterly performance reports for the Shelter and Services Program (SSP) totaling $3,092,423. Despite lacking internal control procedures, we did not identify inaccurate program information reported to the federal agency. Effect—Without effective internal control procedures in place, there is an increased risk that the Department may not prevent or detect and correct errors on reports it submits to federal agencies, which rely on them to effectively monitor the program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ success. Further, the Department is at risk that this finding applies to other federal programs it administers. For instance, in finding 2024-104, we found errors in its reports for the Emergency Rental Assistance Program and Coronavirus State and Local Fiscal Recovery Funds federal programs the Department also administers. Cause—The Department’s management reported that it had performed independent reviews and approvals of all reports but did not maintain documentation of these independent reviews because the Department did not have a formal policy requiring a documented review and approval of its reports. Criteria—Federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). This would include developing, documenting, and implementing internal control procedures to monitor compliance with federal agency guidelines requiring the Department to report accurate and complete information for the LTCF annual obligation and expenditure report and SSP quarterly financial and performance reports.1,2 Recommendations to the Department—The Department should develop, document, and implement policies and procedures, and train responsible employees, to monitor compliance with the programs’ reporting requirements, including processes to perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure reports are accurate, agree to County records, and contain only allowable expenditures. The County's corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of the Treasury. [2022, September]. Reporting Guidance for the Local Assistance and Tribal Consistency Fund. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/LATCF-Reporting-Guidance.pdf. 2 U.S. Department of Homeland Security. [2023, June]. The Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) Fiscal Year 2023 Shelter and Services Program.
Finding 2024-005: Reporting (Significant Deficiency) Information on the Federal Program: 93.368 Criteria: As noted in 2 CFR §200.303 "The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: We noted that while the Foundation does not have a formal review and approval process in place over performance and financial reports that is documented and available for examination. Cause: The Foundation does not document their review and approval process over performance and financial reports. Effect or Potential Effect: Without the proper approval processes in place over performance and financial reports, there exists the potential for reporting errors. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork performed over a sample of reports required to be submitted during the year under audit. We consider our sample to be representative of the population. The issue appears to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation ensure that all approvals over performance and financial reporting are clearly documented and available for examination.
Finding 2024-007 Federal Award Management and Internal Controls (Material Weakness) Information on the Federal Program: 93.368 Criteria: As noted in 2 CFR §200.303 "The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our audit, we noted that management was unable to prepare the Schedule of Expenditures of Federal Awards (SEFA) without assistance. In addition, we noted that formalized, documented internal control policies have not been established over various areas of Federal award management. Cause: The Foundation's controls are not adequately designed, and staff within the Foundation are not properly trained on Federal award management and reporting. Effect or Potential Effect: Without the proper controls in place, there exists the potential for reporting errors and the misappropriation of funds. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend the Foundation formalize internal control procedures over all compliance areas that are adequately communicated to staff. In addition, the Foundation should ensure all staff are properly trained on Federal award management and reporting.
Finding 2024-001 – Procurement Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No.: No. 21.027 Federal Award Number: ASST_NON_SLFRP0137_2001 Grant Award Period: 9/1/2022 – 8/31/2024 Pass Through Entity: Los Angeles County - Department of Public Health Repeat Finding – No Statistically Valid Sample – The sample was not intended to be, and was not, a statistically valid sample Criteria 2 CFR 200.324 requires that the non-federal entity perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold, including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.303 requires the recipient of federal funds establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition/Context For both of the samples selected for testing which had related procurements above the California Community Foundation’s (the Foundation's) Simplified Acquisition Threshold, there was no support evidencing a cost or price analysis performed by management before receiving the corresponding proposals, although multiple bids were received as part of these procurements. Cause Although the Foundation included the requirement in its procurement policies that the cost or price analysis needed to be performed before bids or proposals are received the Foundation did not have sufficient controls in place to ensure that a cost or price analysis is performed prior to receiving bids or proposals. Effect Because the Foundation was not in compliance with one of the procurement requirements this could result in disallowed costs if procurement amounts aren't considered reasonable. The Foundation did, however, receive multiple bids as part of the procurement process for each of the samples noted above to demonstrate the costs claimed for reimbursement under the contract were reasonable and under the budget provided to the Foundation by the passthrough awarding entity. Questioned Costs None noted. Auditors’ Recommendation We recommend that the Foundation strengthen processes and internal controls to ensure that a cost or price analysis is performed, reviewed, and substantiated with formal documentation prior to receiving bids or proposals for all procurement actions above the Simplified Acquisition Threshold. Views of Responsible Officials The Foundation acknowledges the finding and will enhance compliance with federal procurement standards by reinforcing staff training on cost and price analysis requirements, strengthening internal oversight mechanisms, and implementing a formalized process to ensure proper documentation is completed and retained. Periodic reviews and audits will verify adherence to these standards and maintain consistent implementation.
Finding 2024-002 – Allowable Costs Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No.: No. 21.027 Federal Award Number: ASST_NON_SLFRP0137_2001 Grant Award Period: 9/1/2022 – 8/31/2024 Pass Through Entity: Los Angeles County - Department of Public Health Repeat Finding: No Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample Criteria 2 CFR 200.303 requires the recipient of federal funds establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition/Context For 1 of the 28 invoices reviewed, which includes 25 subrecipient invoices and 3 vendor invoices, representing $76,549 of the $439,088 of underlying invoices reviewed, we noted that there was insufficient documentation to demonstrate management completed the invoice review process as the review and approval of this invoice was not documented. The Foundation had an agreement with its contractor to pay for services performed according to an agreed payment schedule. While the Foundation reviewed payments made to the contractors, it did not review the underlying invoice detailing the work performed for the payment. Cause Although the Foundation has a process in place to review invoices for allowability of the underlying costs, management inadvertently failed to formally document their review of one of the invoices we selected for testing. Effect or Potential Effect By not maintain formal evidence that a review of an invoice, there is a risk that costs could be charged to the grant that are ultimately deemed unallowable. Questioned Costs None noted. Auditors’ Recommendation We recommend that the Foundation strengthen its documentation requirements over the review and approval of invoices for costs claimed for federal reimbursement. Views of Responsible Officials The Foundation acknowledges the finding and will implement corrective measures by updating its invoice review procedures to formally record review dates and approvals in compliance with 2 CFR 200.303. Additionally, we will reinforce staff training and supervisory reviews to ensure that all invoice documentation meets federal standards, and we will conduct periodic internal reviews and audits to verify adherence to these enhanced procedures. These actions will mitigate the risk of unallowable cost charges and ensure ongoing compliance with federal procurement standards.
Finding 2024-003 – Reporting Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No.: No. 21.027 Federal Award Number: ASST_NON_SLFRP0137_2001 Grant Award Period: 9/1/2022 – 8/31/2024 Pass Through Entity: Los Angeles County - Department of Public Health Repeat Finding: No Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample Criteria As set forth in 2 CFR 200.328 and in 31 CFR Section 35.4(c), entities receiving Coronavirus State and Local Fiscal Recovery Funds are required to submit quarterly and annually project and expenditure reports to meet compliance and reporting responsibilities under the program. As the Foundation is a subrecipient to the County of Los Angeles (the County), section 6.2 and section 7.0 of Exhibit A of the Agreement between the County and the Foundation for American Rescue Plan Act Trauma Prevention Partnerships provides the reporting requirements by the Foundation to the County including, among other things, the expenditures reported to date by the Foundation. 2 CFR 200.303 requires the recipient of federal funds establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition/Context During fiscal the fiscal year ending June 30, 2024, the Foundation overstated expenditures incurred by its two vendors by $203,629 and a corresponding overstatement of $20,363 in indirect costs in the schedule of expenditures of federal awards (SEFA). Additionally, in the June 30, 2024 Quarterly Performance Report to the County, the Foundation overstated the advances to its vendors by $120,000 and understated expenditures incurred by its two vendors by $519,259. Finally, in the June 30, 2024 Quarterly Invoice to the County, the Foundation overstated the amounts advances to its vendors by $120,000 (however the remaining $807,000 of advances were correctly reported.) Management also failed to separately report the actual expenditures incurred by the vendors in the "Contracts" section of the invoice. However, in the total invoiced amount summarized in the invoice for fiscal 2024 approximated the total expenditures on the June 30, 2024 schedule of expenditures of federal awards. Based on our discussion with management, we understand that the Foundation and the County mutually understood that the June 30, 2024 quarterly invoice was preliminary, as it was submitted by CCF prior to the fiscal year-end. Consequently, the Foundation reflected the final expenditures and payments in the September 30, 2024 invoice. In this invoice, the Foundation removed the previously overstated amount of $120,000 of advances to a vendor. Cause The Foundation had reported all of the amounts advanced to its two vendors in the SEFA and in its quarterly reporting to the County with the understanding that those amounts were the actual expenditures incurred by the vendors during the year. Additionally, there were not sufficient controls in place to ensure that the amounts reported in the SEFA and June 30, 2024 quarterly performance report submitted to the County reconciled to the actual expenditures incurred by the Foundation’s vendors for the year ending June 30, 2024. Effect or Potential Effect The expenditures reported in the schedule of expenditures of federal awards for the year ended June 30, 2024 and in quarterly reporting to the County were incorrect. Questioned Costs None noted. Auditors’ Recommendation We recommend that the Foundation strengthen its reconciliation controls between the amounts reported in the SEFA and County invoices to ensure the amounts are accurate and consistently reported. Views of Responsible Officials CCF acknowledges the finding and is implementing corrective measures to strengthen the accuracy and integrity of its financial and programmatic reporting. CCF has enhanced its internal review process and implemented a reconciliation protocol to ensure consistency between internal records and external reports. Finance staff have received additional training, and final reports are now subject to dual validation by both the Compliance and Finance teams prior to submission.
U.S. Department of Health and Human Services Federal Financial Assistance Listing Number 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services - 1H79SM088927-01 Procurement and Suspension and Debarment Material Weakness in Internal Control over Compliance and Noncompliance Criteria The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity must establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.318 through 200.327. Condition The Organization did not have a written procurement policy that was consistent with Federal, State, local, and tribal laws and regulations. In addition, the Organization entered into a contract with a vendor for services without obtaining quotes from other vendors. Cause There is a lack of controls over the written procurement, suspension and debarment policy and over procurement, suspension and debarment as a whole. Effect Failure to maintain a written procurement policy that was consistent with Federal, State, local, and tribal laws and regulations may result in disallowed costs. Questioned Costs $37,000 was paid during fiscal year 2024 to a vendor without obtaining quotes. Context/Sampling EB reviewed the procurement, suspension and debarment policy. A nonstatistical sample of 3 vendors were selected for testing. Of these 3, 1 did not follow appropriate procurement, suspension and debarment procedures. Repeat Finding from Prior Year(s) Yes Recommendation We recommend that management implement a written procurement, suspension and debarment policy that meets Federal, State, local, and tribal laws and regulations. We recommend that management review this policy regularly to confirm that it meets the requirements. We also recommend that management review this policy prior to entering into any contracts with vendors. Views of Responsible Individuals Management agrees with the finding.
Finding 2024-003 Significant Deficiency – Internal Controls – SUSPENSION AND DEBARMENT ALN 10.555 Child Nutrition Program United States Department of Agriculture Passed through State of Louisiana Department of Education 2024 Funding Criteria: In accordance with 2 CFR Part 200.303(a), the School must establish, document, and maintain effective internal control over Federal awards that provide reasonable assurance that the recipient of subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, in accordance with 2 CFR 200.206(d), the School must comply with the government-wide suspension and debarment guidance in 2CFR Part 180 and individual Federal agency suspension and debarment requirements in title 2 of the Code of Federal Regulations. These requirements restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving Federal awards or participating in Federal awards. Condition: Documentation of proper review for suspension and debarment was not maintained for 3 of 3 vendors tested as required. Cause: The School did not maintain documentation of its review of vendors for suspension and debarment prior to contracting with them for work performed under Federal awards. Effect: Documentation of a review for suspension and debarment was not maintained for vendors with contracts under Federal awards. Questioned costs: None Recommendation: We recommend that the School maintain documentation of its review for suspension and debarment for all vendors with contracts under Federal awards. Management Response: See corrective action plan at page 38.
U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds Applicable Federal Award Number and Year – H4HRG23166 and H4HRGP23180 – 2024 Matching, Level of Effort, Earmarking Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. This includes proper tracking and monitoring of matching expenditure requirements. Condition: During our testing, it was identified the Organization did not have a formal tracking and monitoring process to accumulate total matching expenditures incurred towards the requirement for each award. Cause: The Organization has limited grants with matching requirements, therefore formal processes for tracking were not implemented. Effect: The Organization’s internal controls failed to adequately monitor and track the matching expenses incurred to ensure compliance with the award requirements. Questioned Costs: None reported. Context/Sampling: Not applicable. Repeat Finding from Prior Year: No Recommendation: The Organization should implement internal controls to ensure matching expenditures are tracked throughout the award period and to ensure matching requirements of individual awards are complied with. Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds Applicable Federal Award Number and Year – H4HRG23166 and H4HRGP23180 – 2024 Matching, Level of Effort, Earmarking Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. This includes proper tracking and monitoring of matching expenditure requirements. Condition: During our testing, it was identified the Organization did not have a formal tracking and monitoring process to accumulate total matching expenditures incurred towards the requirement for each award. Cause: The Organization has limited grants with matching requirements, therefore formal processes for tracking were not implemented. Effect: The Organization’s internal controls failed to adequately monitor and track the matching expenses incurred to ensure compliance with the award requirements. Questioned Costs: None reported. Context/Sampling: Not applicable. Repeat Finding from Prior Year: No Recommendation: The Organization should implement internal controls to ensure matching expenditures are tracked throughout the award period and to ensure matching requirements of individual awards are complied with. Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds Applicable Federal Award Number and Year – H4HRG23166 and H4HRGP23180 – 2024 Matching, Level of Effort, Earmarking Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. This includes proper tracking and monitoring of matching expenditure requirements. Condition: During our testing, it was identified the Organization did not have a formal tracking and monitoring process to accumulate total matching expenditures incurred towards the requirement for each award. Cause: The Organization has limited grants with matching requirements, therefore formal processes for tracking were not implemented. Effect: The Organization’s internal controls failed to adequately monitor and track the matching expenses incurred to ensure compliance with the award requirements. Questioned Costs: None reported. Context/Sampling: Not applicable. Repeat Finding from Prior Year: No Recommendation: The Organization should implement internal controls to ensure matching expenditures are tracked throughout the award period and to ensure matching requirements of individual awards are complied with. Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds Applicable Federal Award Number and Year – H4HRG23166 and H4HRGP23180 – 2024 Matching, Level of Effort, Earmarking Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. This includes proper tracking and monitoring of matching expenditure requirements. Condition: During our testing, it was identified the Organization did not have a formal tracking and monitoring process to accumulate total matching expenditures incurred towards the requirement for each award. Cause: The Organization has limited grants with matching requirements, therefore formal processes for tracking were not implemented. Effect: The Organization’s internal controls failed to adequately monitor and track the matching expenses incurred to ensure compliance with the award requirements. Questioned Costs: None reported. Context/Sampling: Not applicable. Repeat Finding from Prior Year: No Recommendation: The Organization should implement internal controls to ensure matching expenditures are tracked throughout the award period and to ensure matching requirements of individual awards are complied with. Views of Responsible Officials: Management agrees with the finding.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-002 – Allowability – Significant deficiency Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committeeof Sponsoring Organizations of the Treadway Commission (COSO).Conditions Found: I. Indirect Cost Expenditures (IDC): To ensure compliance with federally funded grants, particularly concerning indirect cost rates, the institution must adhere to specific criteria. Firstly, compliance with the Uniform Guidance (2 CFR Part 200) is essential. This regulation establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities. The institution must follow these guidelines, which include the proper application and calculation of indirect cost rates. Additionally, adherence to approved indirect cost rates as specified in 2 CFR 200.414 is required. The institution must apply the federally approved indirect cost rates when charging costs to federal awards, ensuring that any deviations, such as using a de minimis rate, are appropriately justified and documented.During our audit we found 3 out of 15 samples selected for our compliance testwork, the College used an incorrect IDC rate. This represents an overcharge, as the IDC rate is intended to cover general administrative expenses that cannot be directly attributed to a specific project. In utilizing a higher rate, the College effectively inflated the administrative costs charged to the federal grants. II. Fringe Rates: When applying fringe rates to federally funded R&D grants, institutions must comply with specific laws, regulations, and requirements to ensure adherence to federal guidelines. The primary regulatory framework is outlined in the OMB Uniform Guidance (2CFR Part 200), which provides the Uniform Administrative Requirements, Cost Principles,and Audit Requirements for Federal Awards. This regulation specifies that fringe benefits,which include employee-related expenses such as health insurance and retirement contributions, are allowable costs only if they are necessary, reasonable, and allocable to the federal award. Additionally, the Federal Acquisition Regulation (FAR) Part 31 outlines the cost principles and procedures for determining the allowability of costs under government contracts, reinforcing the need for costs to be necessary, reasonable, and allocable. Institutions must apply fringe benefit rates that align with the approved rates set by the overseeing federal agency. Overcharging or applying incorrect rates can result in noncompliance with federal regulations. Adequate internal controls are necessary to ensure the correct application of fringe rates, which includes regular monitoring and verification. In cases of noncompliance, corrective actions must be taken to address and rectify discrepancies. Proper documentation and recordkeeping are also essential to support the application of fringe rates and demonstrate compliance with federal guidelines. During our audit we found 5 out of 20 samples selected for our compliance testwork, the College charged an incorrect fringe rate. After inquiry of management, we noted during thefirst quarter of the period under audit, the College charged a fringe benefit rate of 19.9%,instead of the actual rate of 18.65%. KPMG noted for our 15 of 20 samples which were incurred during quarters two, three, and four, the appropriate fringe rate was utilized. Cause: I. Indirect Cost Expenditures (IDC): The cause of the condition is that the College’s internal controls over the review of the rates applied to calculate the IDC charges were not operating effectively to the awards throughout the year. The College manually calculates what the IDC costs are based upon outdated rates and was booked into their financial reporting system without a supplemental review or reconciliation. II. Fringe Rates: The cause of the condition found is the institution not maintaining appropriately functioning controls to review the rates applied to the fringe benefit charges applied to theawards throughout the year. The College manually reviews the fringe benefits charges afterthe expenditure process and therefore is not designed to catch noncompliance prior to the charges to grant. The College identified they were using the incorrect fringe rates during the first quarter, however, did not go back and correct the error as they deemed it to be immaterial. Possible Asserted Effect: I. Indirect Cost Expenditures (IDC): The inflated rate has led to an unwarranted increase in administrative costs charged to federal grants, potentially resulting in the overcharge. II. Fringe Rates: The possible effect of the condition found is that the Institution is overcharging future federal grants for an excess of fringe more than what is deemed as allowable. Questioned Costs The known questioned costs are $3,835 (IDC known questioned costs are $1,703 and fringe known questioned costs are $2,132) and the likely questioned costs are $4,767. Statistical Sampling: Neither samples were intended to be, and were not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: I. Indirect Cost Expenditures (IDC): We recommend that management review its internal controls and establish a routine audit and monitoring process to regularly review the application of indirect cost rates and ensure compliance with federal regulations.
Finding No.: 2024-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count .Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process.Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance withthe guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our audit, we sampled and tested the equipment listing and discovered that 1 out of 11samples selected for testing could not be located while on site at Union College as the equipmentitem's actual storage location had not been updated in the College's master listing appropriately.Additionally, we were informed that the equipment is no longer functional and should have been disposed of, but it had not been, showing a failure to maintain accurate records of federally acquired equipment and dispose of equipment according to compliance requirements. Cause: The cause of the condition found that the College did not follow its policies to conduct a physical inventory count, resulting in discrepancies in the equipment listing as well as a lack of formally written policies and procedures to update and report changes in equipment status at the College. Possible Asserted Effect: The inability to locate equipment and improper disposal practices compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs: No questioned costs were identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: We recommend that management perform a thorough physical inventory audit to locate all equipmentand update the master equipment listing with accurate details, including current locations and statuses .Additionally, we recommend the institution review and regularly circulate a formal plan for the appropriate disposal of non-functional or obsolete equipment. This plan should include obtaining necessary approvals and documenting the disposal process as per federal guidelines. Views of Responsible Officials: Recommendation accepted.
Finding No.: 2024-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count .Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process.Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance withthe guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our audit, we sampled and tested the equipment listing and discovered that 1 out of 11samples selected for testing could not be located while on site at Union College as the equipmentitem's actual storage location had not been updated in the College's master listing appropriately.Additionally, we were informed that the equipment is no longer functional and should have been disposed of, but it had not been, showing a failure to maintain accurate records of federally acquired equipment and dispose of equipment according to compliance requirements. Cause: The cause of the condition found that the College did not follow its policies to conduct a physical inventory count, resulting in discrepancies in the equipment listing as well as a lack of formally written policies and procedures to update and report changes in equipment status at the College. Possible Asserted Effect: The inability to locate equipment and improper disposal practices compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs: No questioned costs were identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: We recommend that management perform a thorough physical inventory audit to locate all equipmentand update the master equipment listing with accurate details, including current locations and statuses .Additionally, we recommend the institution review and regularly circulate a formal plan for the appropriate disposal of non-functional or obsolete equipment. This plan should include obtaining necessary approvals and documenting the disposal process as per federal guidelines. Views of Responsible Officials: Recommendation accepted.
Finding No.: 2024-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count .Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process.Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance withthe guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our audit, we sampled and tested the equipment listing and discovered that 1 out of 11samples selected for testing could not be located while on site at Union College as the equipmentitem's actual storage location had not been updated in the College's master listing appropriately.Additionally, we were informed that the equipment is no longer functional and should have been disposed of, but it had not been, showing a failure to maintain accurate records of federally acquired equipment and dispose of equipment according to compliance requirements. Cause: The cause of the condition found that the College did not follow its policies to conduct a physical inventory count, resulting in discrepancies in the equipment listing as well as a lack of formally written policies and procedures to update and report changes in equipment status at the College. Possible Asserted Effect: The inability to locate equipment and improper disposal practices compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs: No questioned costs were identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: We recommend that management perform a thorough physical inventory audit to locate all equipmentand update the master equipment listing with accurate details, including current locations and statuses .Additionally, we recommend the institution review and regularly circulate a formal plan for the appropriate disposal of non-functional or obsolete equipment. This plan should include obtaining necessary approvals and documenting the disposal process as per federal guidelines. Views of Responsible Officials: Recommendation accepted.
Finding No.: 2024-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count .Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process.Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance withthe guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our audit, we sampled and tested the equipment listing and discovered that 1 out of 11samples selected for testing could not be located while on site at Union College as the equipmentitem's actual storage location had not been updated in the College's master listing appropriately.Additionally, we were informed that the equipment is no longer functional and should have been disposed of, but it had not been, showing a failure to maintain accurate records of federally acquired equipment and dispose of equipment according to compliance requirements. Cause: The cause of the condition found that the College did not follow its policies to conduct a physical inventory count, resulting in discrepancies in the equipment listing as well as a lack of formally written policies and procedures to update and report changes in equipment status at the College. Possible Asserted Effect: The inability to locate equipment and improper disposal practices compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs: No questioned costs were identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: We recommend that management perform a thorough physical inventory audit to locate all equipmentand update the master equipment listing with accurate details, including current locations and statuses .Additionally, we recommend the institution review and regularly circulate a formal plan for the appropriate disposal of non-functional or obsolete equipment. This plan should include obtaining necessary approvals and documenting the disposal process as per federal guidelines. Views of Responsible Officials: Recommendation accepted.
Finding No.: 2024-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count .Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process.Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance withthe guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our audit, we sampled and tested the equipment listing and discovered that 1 out of 11samples selected for testing could not be located while on site at Union College as the equipmentitem's actual storage location had not been updated in the College's master listing appropriately.Additionally, we were informed that the equipment is no longer functional and should have been disposed of, but it had not been, showing a failure to maintain accurate records of federally acquired equipment and dispose of equipment according to compliance requirements. Cause: The cause of the condition found that the College did not follow its policies to conduct a physical inventory count, resulting in discrepancies in the equipment listing as well as a lack of formally written policies and procedures to update and report changes in equipment status at the College. Possible Asserted Effect: The inability to locate equipment and improper disposal practices compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs: No questioned costs were identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: We recommend that management perform a thorough physical inventory audit to locate all equipmentand update the master equipment listing with accurate details, including current locations and statuses .Additionally, we recommend the institution review and regularly circulate a formal plan for the appropriate disposal of non-functional or obsolete equipment. This plan should include obtaining necessary approvals and documenting the disposal process as per federal guidelines. Views of Responsible Officials: Recommendation accepted.
Finding No.: 2024-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count .Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process.Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance withthe guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our audit, we sampled and tested the equipment listing and discovered that 1 out of 11samples selected for testing could not be located while on site at Union College as the equipmentitem's actual storage location had not been updated in the College's master listing appropriately.Additionally, we were informed that the equipment is no longer functional and should have been disposed of, but it had not been, showing a failure to maintain accurate records of federally acquired equipment and dispose of equipment according to compliance requirements. Cause: The cause of the condition found that the College did not follow its policies to conduct a physical inventory count, resulting in discrepancies in the equipment listing as well as a lack of formally written policies and procedures to update and report changes in equipment status at the College. Possible Asserted Effect: The inability to locate equipment and improper disposal practices compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs: No questioned costs were identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: We recommend that management perform a thorough physical inventory audit to locate all equipmentand update the master equipment listing with accurate details, including current locations and statuses .Additionally, we recommend the institution review and regularly circulate a formal plan for the appropriate disposal of non-functional or obsolete equipment. This plan should include obtaining necessary approvals and documenting the disposal process as per federal guidelines. Views of Responsible Officials: Recommendation accepted.
Finding No.: 2024-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count .Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process.Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance withthe guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our audit, we sampled and tested the equipment listing and discovered that 1 out of 11samples selected for testing could not be located while on site at Union College as the equipmentitem's actual storage location had not been updated in the College's master listing appropriately.Additionally, we were informed that the equipment is no longer functional and should have been disposed of, but it had not been, showing a failure to maintain accurate records of federally acquired equipment and dispose of equipment according to compliance requirements. Cause: The cause of the condition found that the College did not follow its policies to conduct a physical inventory count, resulting in discrepancies in the equipment listing as well as a lack of formally written policies and procedures to update and report changes in equipment status at the College. Possible Asserted Effect: The inability to locate equipment and improper disposal practices compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs: No questioned costs were identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: We recommend that management perform a thorough physical inventory audit to locate all equipmentand update the master equipment listing with accurate details, including current locations and statuses .Additionally, we recommend the institution review and regularly circulate a formal plan for the appropriate disposal of non-functional or obsolete equipment. This plan should include obtaining necessary approvals and documenting the disposal process as per federal guidelines. Views of Responsible Officials: Recommendation accepted.
Finding No.: 2024-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count .Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process.Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance withthe guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our audit, we sampled and tested the equipment listing and discovered that 1 out of 11samples selected for testing could not be located while on site at Union College as the equipmentitem's actual storage location had not been updated in the College's master listing appropriately.Additionally, we were informed that the equipment is no longer functional and should have been disposed of, but it had not been, showing a failure to maintain accurate records of federally acquired equipment and dispose of equipment according to compliance requirements. Cause: The cause of the condition found that the College did not follow its policies to conduct a physical inventory count, resulting in discrepancies in the equipment listing as well as a lack of formally written policies and procedures to update and report changes in equipment status at the College. Possible Asserted Effect: The inability to locate equipment and improper disposal practices compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs: No questioned costs were identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: We recommend that management perform a thorough physical inventory audit to locate all equipmentand update the master equipment listing with accurate details, including current locations and statuses .Additionally, we recommend the institution review and regularly circulate a formal plan for the appropriate disposal of non-functional or obsolete equipment. This plan should include obtaining necessary approvals and documenting the disposal process as per federal guidelines. Views of Responsible Officials: Recommendation accepted.
Finding No.: 2024-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count .Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process.Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance withthe guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our audit, we sampled and tested the equipment listing and discovered that 1 out of 11samples selected for testing could not be located while on site at Union College as the equipmentitem's actual storage location had not been updated in the College's master listing appropriately.Additionally, we were informed that the equipment is no longer functional and should have been disposed of, but it had not been, showing a failure to maintain accurate records of federally acquired equipment and dispose of equipment according to compliance requirements. Cause: The cause of the condition found that the College did not follow its policies to conduct a physical inventory count, resulting in discrepancies in the equipment listing as well as a lack of formally written policies and procedures to update and report changes in equipment status at the College. Possible Asserted Effect: The inability to locate equipment and improper disposal practices compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs: No questioned costs were identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: We recommend that management perform a thorough physical inventory audit to locate all equipmentand update the master equipment listing with accurate details, including current locations and statuses .Additionally, we recommend the institution review and regularly circulate a formal plan for the appropriate disposal of non-functional or obsolete equipment. This plan should include obtaining necessary approvals and documenting the disposal process as per federal guidelines. Views of Responsible Officials: Recommendation accepted.
Finding No.: 2024-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count .Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process.Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance withthe guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our audit, we sampled and tested the equipment listing and discovered that 1 out of 11samples selected for testing could not be located while on site at Union College as the equipmentitem's actual storage location had not been updated in the College's master listing appropriately.Additionally, we were informed that the equipment is no longer functional and should have been disposed of, but it had not been, showing a failure to maintain accurate records of federally acquired equipment and dispose of equipment according to compliance requirements. Cause: The cause of the condition found that the College did not follow its policies to conduct a physical inventory count, resulting in discrepancies in the equipment listing as well as a lack of formally written policies and procedures to update and report changes in equipment status at the College. Possible Asserted Effect: The inability to locate equipment and improper disposal practices compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs: No questioned costs were identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: We recommend that management perform a thorough physical inventory audit to locate all equipmentand update the master equipment listing with accurate details, including current locations and statuses .Additionally, we recommend the institution review and regularly circulate a formal plan for the appropriate disposal of non-functional or obsolete equipment. This plan should include obtaining necessary approvals and documenting the disposal process as per federal guidelines. Views of Responsible Officials: Recommendation accepted.
Finding No.: 2024-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count .Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process.Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance withthe guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our audit, we sampled and tested the equipment listing and discovered that 1 out of 11samples selected for testing could not be located while on site at Union College as the equipmentitem's actual storage location had not been updated in the College's master listing appropriately.Additionally, we were informed that the equipment is no longer functional and should have been disposed of, but it had not been, showing a failure to maintain accurate records of federally acquired equipment and dispose of equipment according to compliance requirements. Cause: The cause of the condition found that the College did not follow its policies to conduct a physical inventory count, resulting in discrepancies in the equipment listing as well as a lack of formally written policies and procedures to update and report changes in equipment status at the College. Possible Asserted Effect: The inability to locate equipment and improper disposal practices compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs: No questioned costs were identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: We recommend that management perform a thorough physical inventory audit to locate all equipmentand update the master equipment listing with accurate details, including current locations and statuses .Additionally, we recommend the institution review and regularly circulate a formal plan for the appropriate disposal of non-functional or obsolete equipment. This plan should include obtaining necessary approvals and documenting the disposal process as per federal guidelines. Views of Responsible Officials: Recommendation accepted.
Finding No.: 2024-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count .Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process.Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance withthe guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our audit, we sampled and tested the equipment listing and discovered that 1 out of 11samples selected for testing could not be located while on site at Union College as the equipmentitem's actual storage location had not been updated in the College's master listing appropriately.Additionally, we were informed that the equipment is no longer functional and should have been disposed of, but it had not been, showing a failure to maintain accurate records of federally acquired equipment and dispose of equipment according to compliance requirements. Cause: The cause of the condition found that the College did not follow its policies to conduct a physical inventory count, resulting in discrepancies in the equipment listing as well as a lack of formally written policies and procedures to update and report changes in equipment status at the College. Possible Asserted Effect: The inability to locate equipment and improper disposal practices compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs: No questioned costs were identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: The conditions found do not constitute a repeat finding from the prior year. Recommendation: We recommend that management perform a thorough physical inventory audit to locate all equipmentand update the master equipment listing with accurate details, including current locations and statuses .Additionally, we recommend the institution review and regularly circulate a formal plan for the appropriate disposal of non-functional or obsolete equipment. This plan should include obtaining necessary approvals and documenting the disposal process as per federal guidelines. Views of Responsible Officials: Recommendation accepted.