2023-004 - ACTIVITIES ALLOWED OR UNALLOWED / ALLOWABLE COSTS/COST PRINCIPLES Type: Significant Deficiency in Internal Control / Non-compliance Program: ALN 84.425 Education Stabilization Fund, COVID-19 - ESSER II - Formula Criteria: As detailed in 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of grant disbursements, it was noted that a charge for a sound system was not authorized by the grant. The total amount charged to the grant for this purchase was $20,050. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Recommendation: We recommend that the District review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2023-025 Improve Controls over Manual Journal Entries Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Labor Pass-Through Entity: None AL Numbers and Titles: 17.207 – Employment Service/Wagner-Peyser Funded Activities 17.801 – Jobs for Veterans State Grant Federal Award Numbers: ES387252255A13 (Year: 2022), ES367492155A13 (Year: 2021), ES353382055A13 (Year: 2020), ES333881955A13 (Year: 2019), DV35790SG1 (Year: 2020), DV37869SG2 (Year: 2021) Questioned Costs: $1,220,638 Description: The Georgia Department of Labor should improve internal controls over manual journal entries for the Employment Services Cluster. Background Information: The Georgia Department of Labor (DOL) is responsible for the administration and monitoring of Georgia's Employment Services Cluster programs, including carrying out the Employment Services/Wagner-Peyser (ES) funded activities, as well as the Jobs for Veterans State Grant (JVSG) funded activities. The main purpose of the ES program is to improve the functioning of the nation’s labor markets by bringing together individuals seeking employment and employers seeking workers. The main purpose of the JVSG program is to provide career services to meet the employment needs of eligible veterans, to conduct outreach to employers in the area to assist veterans in gaining employment, and to facilitate employment, training, and placement services furnished to veterans. Operation of the Employment Services Cluster programs transferred to the Technical College System of Georgia (TCSG) in January 2023. Criteria: As a recipient of federal awards, the DOL is required to establish and maintain effective internal controls over federal awards that provide reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.402 state, that “the total cost of a federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits.” In addition, provisions included in the Uniform Guidance, Section 200.403(g) state, in part, that costs must “be adequately documented.” Condition: Our audit of the Employment Services Cluster revealed deficiencies related to manual journal entries (MJE) booked to re-rate program expenditures. Auditors identified a population of 70 MJE’s and selected a total of 11 items for testing. Of those 11 MJE’s one item was an individually selected item (ISI) and an additional 10 were randomly selected using a non-statistical sampling method. Auditors found that the one ISI and two of the randomly selected MJEs were for unallowable expenditures given they were charged to the program well after the authority to carry out program activities was transferred to TCSG. Additionally, the one ISI and seven randomly selected MJEs did not have adequate documentation to support the allowability of costs being charged to the program. Questioned Costs: Upon testing a sample of $603,291 of MJE’s, known questioned costs of $383,294 were identified. Using the total population amount of $2,635,054, we project likely questioned costs to be approximately $1,674,153. In addition, known questioned costs identified for the ISI tested totaled $837,344; therefore, the known questioned costs identified for MJE’s throughout the sample and ISI tested totaled $1,220,638. Cause: The Employment Services Cluster moved to TCSG in January 2023, which had already been a delay in transfer to TCSG as it should have been as of July 1, 2022. Based on the actual transfer of the program in January 2023 DOL completed final ETA-9130 reports for the grants transferring to TCSG, which were to be submitted by February 14, 2023. The reports submitted to the U.S. Department of Labor’s Employment and Training Administration by the DOL included expenditures (the three MJE’s noted in the condition section above) that were not incurred until after the programs and program staff had moved to the TCSG and after the actual reports were submitted. Additionally, the existing internal control system in place did not provide adequate documentation to be maintained or provided for the eight additional MJEs identified as unsupported in our testing. Effect: The inclusion of unallowable costs in program expenditures and not maintaining adequate documentation of manual journal entries resulted in noncompliance with federal regulations and the Uniform Guidance. In addition, without effective controls, the DOL increases its risk of charging unallowable costs to federal programs. This may prevent the DOL from effectively administering federal programs in the future. Furthermore, the U.S. Department of Labor may require repayment of costs that are determined to be unallowable, and the State of Georgia could be responsible for such repayment. Recommendation: The DOL should ensure that all current and future business practices follow the established policies and procedures of the Uniform Guidance, the U.S. Department of Labor, and the State of Georgia. Where vulnerable, the DOL should modify its policies and procedures to ensure that costs being charged via manual journal entries are allowable and adequately documented, including original invoices for costs being moved to other federal programs. Furthermore, management should develop and implement a monitoring process to ensure that controls are operating appropriately. Views of Responsible Officials: We concur with this finding.
2023-025 Improve Controls over Manual Journal Entries Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Labor Pass-Through Entity: None AL Numbers and Titles: 17.207 – Employment Service/Wagner-Peyser Funded Activities 17.801 – Jobs for Veterans State Grant Federal Award Numbers: ES387252255A13 (Year: 2022), ES367492155A13 (Year: 2021), ES353382055A13 (Year: 2020), ES333881955A13 (Year: 2019), DV35790SG1 (Year: 2020), DV37869SG2 (Year: 2021) Questioned Costs: $1,220,638 Description: The Georgia Department of Labor should improve internal controls over manual journal entries for the Employment Services Cluster. Background Information: The Georgia Department of Labor (DOL) is responsible for the administration and monitoring of Georgia's Employment Services Cluster programs, including carrying out the Employment Services/Wagner-Peyser (ES) funded activities, as well as the Jobs for Veterans State Grant (JVSG) funded activities. The main purpose of the ES program is to improve the functioning of the nation’s labor markets by bringing together individuals seeking employment and employers seeking workers. The main purpose of the JVSG program is to provide career services to meet the employment needs of eligible veterans, to conduct outreach to employers in the area to assist veterans in gaining employment, and to facilitate employment, training, and placement services furnished to veterans. Operation of the Employment Services Cluster programs transferred to the Technical College System of Georgia (TCSG) in January 2023. Criteria: As a recipient of federal awards, the DOL is required to establish and maintain effective internal controls over federal awards that provide reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.402 state, that “the total cost of a federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits.” In addition, provisions included in the Uniform Guidance, Section 200.403(g) state, in part, that costs must “be adequately documented.” Condition: Our audit of the Employment Services Cluster revealed deficiencies related to manual journal entries (MJE) booked to re-rate program expenditures. Auditors identified a population of 70 MJE’s and selected a total of 11 items for testing. Of those 11 MJE’s one item was an individually selected item (ISI) and an additional 10 were randomly selected using a non-statistical sampling method. Auditors found that the one ISI and two of the randomly selected MJEs were for unallowable expenditures given they were charged to the program well after the authority to carry out program activities was transferred to TCSG. Additionally, the one ISI and seven randomly selected MJEs did not have adequate documentation to support the allowability of costs being charged to the program. Questioned Costs: Upon testing a sample of $603,291 of MJE’s, known questioned costs of $383,294 were identified. Using the total population amount of $2,635,054, we project likely questioned costs to be approximately $1,674,153. In addition, known questioned costs identified for the ISI tested totaled $837,344; therefore, the known questioned costs identified for MJE’s throughout the sample and ISI tested totaled $1,220,638. Cause: The Employment Services Cluster moved to TCSG in January 2023, which had already been a delay in transfer to TCSG as it should have been as of July 1, 2022. Based on the actual transfer of the program in January 2023 DOL completed final ETA-9130 reports for the grants transferring to TCSG, which were to be submitted by February 14, 2023. The reports submitted to the U.S. Department of Labor’s Employment and Training Administration by the DOL included expenditures (the three MJE’s noted in the condition section above) that were not incurred until after the programs and program staff had moved to the TCSG and after the actual reports were submitted. Additionally, the existing internal control system in place did not provide adequate documentation to be maintained or provided for the eight additional MJEs identified as unsupported in our testing. Effect: The inclusion of unallowable costs in program expenditures and not maintaining adequate documentation of manual journal entries resulted in noncompliance with federal regulations and the Uniform Guidance. In addition, without effective controls, the DOL increases its risk of charging unallowable costs to federal programs. This may prevent the DOL from effectively administering federal programs in the future. Furthermore, the U.S. Department of Labor may require repayment of costs that are determined to be unallowable, and the State of Georgia could be responsible for such repayment. Recommendation: The DOL should ensure that all current and future business practices follow the established policies and procedures of the Uniform Guidance, the U.S. Department of Labor, and the State of Georgia. Where vulnerable, the DOL should modify its policies and procedures to ensure that costs being charged via manual journal entries are allowable and adequately documented, including original invoices for costs being moved to other federal programs. Furthermore, management should develop and implement a monitoring process to ensure that controls are operating appropriately. Views of Responsible Officials: We concur with this finding.
Finding 2023-003 – ACTIVITIES ALLOWED OR UNALLOWED and ALLOWABLE COSTS/COST PRINCIPLES Type: Significant Deficiency in Internal Control / Noncompliance Program: COVID 19 Education Stabilization Fund (ALN 84.425D – ESSER II Formula, and ALN 84.425U – ESSER III Formula) Condition: Expenditures charged to the grant were not authorized in the grant budget. Criteria: As detailed by 2 CFR 200.402, “the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits”. Cause: Management’s misunderstanding of costs allowed under this grant. Effect: Unallowed costs were charged to the grant based on / compared to MDE approved budgets. Consequently, reimbursements (funding sources) may be overstated. Context: Amounts expended for these grants by function code and/or object code were over the amounts allowed in the MDE approved budget. Recommendation: We recommend that the District review all grant agreements to gain a thorough understanding of allowable costs and then establish internal controls to assure that only allowable costs are charged to the grant. Management’s Resp: Management is in agreement with this recommendation.
Finding 2023-003 – ACTIVITIES ALLOWED OR UNALLOWED and ALLOWABLE COSTS/COST PRINCIPLES Type: Significant Deficiency in Internal Control / Noncompliance Program: COVID 19 Education Stabilization Fund (ALN 84.425D – ESSER II Formula, and ALN 84.425U – ESSER III Formula) Condition: Expenditures charged to the grant were not authorized in the grant budget. Criteria: As detailed by 2 CFR 200.402, “the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits”. Cause: Management’s misunderstanding of costs allowed under this grant. Effect: Unallowed costs were charged to the grant based on / compared to MDE approved budgets. Consequently, reimbursements (funding sources) may be overstated. Context: Amounts expended for these grants by function code and/or object code were over the amounts allowed in the MDE approved budget. Recommendation: We recommend that the District review all grant agreements to gain a thorough understanding of allowable costs and then establish internal controls to assure that only allowable costs are charged to the grant. Management’s Resp: Management is in agreement with this recommendation.
Emergency Rental Assistance program, CFDA No. 21.023, Grant No. SC-108725: Grant Period October 2021 to September 30, 2022. Type of Compliance Requirement: Allowable Cost/Cost Principles Criteria: 2 CFR 200.402 requires cost must meet criteria in order to be allowable under the federal awards. The criteria includes cost must be determined in accordance with accounting principles, adequately documented and must be incurred during the approved budget period. Condition: The organization had reimbursed rental assistance and other housing costs of $12,650 that were not incurred. Cause: Reimbursements on the federal contract were based on information sheets completed by program staff and not reconciled with actual payments recorded in the general ledger causing incorrect reimbursement. At the same time, the Organization overlooked to fully reimburse indirect costs allowed under the federal award. Questioned costs: $12,650 Identification of repeat findings: Not applicable Recommendation: Coordinate with pass through entity to settle the reimbursement discrepancy. Views of responsible personnel and planned corrective action: management agrees with the findings. See corrective action plan.
Emergency Rental Assistance program, CFDA No. 21.023, Grant No. SC-108725: Grant Period October 2021 to September 30, 2022. Type of Compliance Requirement: Allowable Cost/Cost Principles Criteria: 2 CFR 200.402 requires cost must meet criteria in order to be allowable under the federal awards. The criteria includes cost must be determined in accordance with accounting principles, adequately documented and must be incurred during the approved budget period. Condition: The organization had reimbursed rental assistance and other housing costs of $12,650 that were not incurred. Cause: Reimbursements on the federal contract were based on information sheets completed by program staff and not reconciled with actual payments recorded in the general ledger causing incorrect reimbursement. At the same time, the Organization overlooked to fully reimburse indirect costs allowed under the federal award. Questioned costs: $12,650 Identification of repeat findings: Not applicable Recommendation: Coordinate with pass through entity to settle the reimbursement discrepancy. Views of responsible personnel and planned corrective action: management agrees with the findings. See corrective action plan.
2022-002 – Activities Allowed/Allowable Costs Finding Type: Significant Deficiency in internal control over compliance Program: ALN 93.959 – Prevention, Women’s Specialty Services, Administration Criteria: As required by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: For the timecard tested, all paid time off was charged to the grant. However, based on the percentage allocations in the timecard, only a portion should have been charged to the grant. Cause/Effect: Management oversight. Unallowable costs were charged to the grant. Questioned Cost: None. Recommendation: We recommend that the Entity review the internal controls over approval of payroll costs and modify them, if necessary, to assure that only allowable costs are charged to grants. View of Responsible Official: Management is in agreement with this recommendation.
2022-001: Considered a significant deficiency in internal control/immaterial non-compliance Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (Community Grant) Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that provider stabilization payments were charged to Community Grant but were not authorized by the grant. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $199,598. Recommendation: We recommend that the Entity review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2022-001: Considered a significant deficiency in internal control/immaterial non-compliance Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (Treatment and Access Management; Women?s Specialty Services) Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that provider stabilization payments were charged to the Treatment and Women?s Specialty Services grants but were not authorized by the grants. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $289,629 (Treatment and Access Management: $275,928, Women?s Specialty Services: $13,701). Recommendation: We recommend that the Entity review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2022-001: Considered a significant deficiency in internal control/immaterial non-compliance Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (Treatment and Access Management; Women?s Specialty Services) Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that provider stabilization payments were charged to the Treatment and Women?s Specialty Services grants but were not authorized by the grants. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $289,629 (Treatment and Access Management: $275,928, Women?s Specialty Services: $13,701). Recommendation: We recommend that the Entity review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2022-002 – Activities Allowed/Allowable Costs Finding Type: Significant Deficiency in internal control over compliance Program: ALN 93.959 – Prevention, Women’s Specialty Services, Administration Criteria: As required by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: For the timecard tested, all paid time off was charged to the grant. However, based on the percentage allocations in the timecard, only a portion should have been charged to the grant. Cause/Effect: Management oversight. Unallowable costs were charged to the grant. Questioned Cost: None. Recommendation: We recommend that the Entity review the internal controls over approval of payroll costs and modify them, if necessary, to assure that only allowable costs are charged to grants. View of Responsible Official: Management is in agreement with this recommendation.
2022-001: Considered a significant deficiency in internal control/immaterial non-compliance Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (Community Grant) Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that provider stabilization payments were charged to Community Grant but were not authorized by the grant. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $199,598. Recommendation: We recommend that the Entity review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2022-001: Considered a significant deficiency in internal control/immaterial non-compliance Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (Treatment and Access Management; Women?s Specialty Services) Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that provider stabilization payments were charged to the Treatment and Women?s Specialty Services grants but were not authorized by the grants. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $289,629 (Treatment and Access Management: $275,928, Women?s Specialty Services: $13,701). Recommendation: We recommend that the Entity review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2022-001: Considered a significant deficiency in internal control/immaterial non-compliance Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (Treatment and Access Management; Women?s Specialty Services) Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that provider stabilization payments were charged to the Treatment and Women?s Specialty Services grants but were not authorized by the grants. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $289,629 (Treatment and Access Management: $275,928, Women?s Specialty Services: $13,701). Recommendation: We recommend that the Entity review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
Finding 2022-300: Disaster Grants?Public Assistance (Presidentially Declared Disasters)?Unallowable Costs Background: In February 2021, a presidential memorandum was issued extending certain federal support to increase the reimbursement and other assistance provided by the Federal Emergency Management Agency (FEMA) to states in order to combat COVID-19. The memorandum allowed FEMA to pay 100 percent of the costs of activities that had previously been determined to be eligible from the beginning of the public health emergency in January 2020. This funding was provided through the Disaster Grants?Public Assistance (Presidentially Declared Disasters) grant (Assistance Listing number 97.036). As a result, DHS changed the funding source of certain expenditures from a prior fiscal year by moving them to this grant in FY 2021-22. Criteria: Under 2 CFR 200.403, costs charged to a federal award must be necessary and reasonable for the performance of the federal award and be adequately documented. In addition, 2 CFR 200.402 requires that these costs must be reduced by any applicable credits, such as refunds for overpayments. Condition: In information submitted to FEMA to support reimbursement for costs related to personal protective equipment, we identified that DHS received reimbursements for transactions totaling $855,368 that should not have been included in its reimbursement request. Specifically, we found that DHS included a $395,000 payment for which it received a refund from the vendor. In addition, we found that DHS included a payment for $460,368 twice within the supporting documentation it provided to FEMA for its reimbursement request. Context: During FY 2021-22, DHS received reimbursements for costs associated with the public health emergency totaling $154.4 million from the Disaster Grants?Public Assistance (Presidentially Declared Disasters) grant. We reviewed the supporting documentation for the two largest reimbursements and tested a selection of expenditures. Questioned Costs: $855,368 Effect: Because it received Disaster Grants?Public Assistance (Presidentially Declared Disasters) grant funding for inappropriate expenditure transactions, DHS was not in compliance with federal requirements. Cause: The inappropriate expenditure transactions we identified were included in the first large reimbursement request prepared by DHS, which was based on information provided by another state agency. At the time of this reimbursement request, DHS did not have procedures in place to identify duplicate or refunded payments within the data used to support the reimbursement request. DHS staff indicated that subsequent reimbursement requests were prepared using DHS queries from STAR, which is the State?s accounting system, that removed duplicated or refunded transactions. We did not identify issues in the other reimbursement request we reviewed. Recommendation: We recommend the Wisconsin Department of Health Services work with the federal government to resolve the $855,368 in unallowable costs we identified. Finding 2022-300: Disaster Grants?Public Assistance (Presidentially Declared Disasters)?Unallowable Costs COVID-19?Disaster Grants?Public Assistance (Presidentially Declared Disasters) (Assistance Listing number 97.036) Award Number Award Year 4650DR4520PA 2022 Questioned Costs: $855,368 Type of Finding: Noncompliance Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
2022-001 - ACTIVITIES ALLOWED OR UNALLOWED / ALLOWABLE COSTS/COST PRINCIPLES Program: ALN 84.425 Education Stabilization Fund, ESSER II - Formula Type: Material Weakness in Internal Control / Non-Compliance Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that payments were charged to the grant but were not authorized by the grant. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $104,101 Recommendation: We recommend that the District review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2022-001 - ACTIVITIES ALLOWED OR UNALLOWED / ALLOWABLE COSTS/COST PRINCIPLES Program: ALN 84.425 Education Stabilization Fund, ESSER II - Formula Type: Material Weakness in Internal Control / Non-Compliance Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that payments were charged to the grant but were not authorized by the grant. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $104,101 Recommendation: We recommend that the District review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2022-001 - ACTIVITIES ALLOWED OR UNALLOWED / ALLOWABLE COSTS/COST PRINCIPLES Program: ALN 84.425 Education Stabilization Fund, ESSER II - Formula Type: Material Weakness in Internal Control / Non-Compliance Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that payments were charged to the grant but were not authorized by the grant. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $104,101 Recommendation: We recommend that the District review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2022-001 - ACTIVITIES ALLOWED OR UNALLOWED / ALLOWABLE COSTS/COST PRINCIPLES Program: ALN 84.425 Education Stabilization Fund, ESSER II - Formula Type: Material Weakness in Internal Control / Non-Compliance Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that payments were charged to the grant but were not authorized by the grant. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $104,101 Recommendation: We recommend that the District review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
Finding 2022-300: Disaster Grants?Public Assistance (Presidentially Declared Disasters)?Unallowable Costs Background: In February 2021, a presidential memorandum was issued extending certain federal support to increase the reimbursement and other assistance provided by the Federal Emergency Management Agency (FEMA) to states in order to combat COVID-19. The memorandum allowed FEMA to pay 100 percent of the costs of activities that had previously been determined to be eligible from the beginning of the public health emergency in January 2020. This funding was provided through the Disaster Grants?Public Assistance (Presidentially Declared Disasters) grant (Assistance Listing number 97.036). As a result, DHS changed the funding source of certain expenditures from a prior fiscal year by moving them to this grant in FY 2021-22. Criteria: Under 2 CFR 200.403, costs charged to a federal award must be necessary and reasonable for the performance of the federal award and be adequately documented. In addition, 2 CFR 200.402 requires that these costs must be reduced by any applicable credits, such as refunds for overpayments. Condition: In information submitted to FEMA to support reimbursement for costs related to personal protective equipment, we identified that DHS received reimbursements for transactions totaling $855,368 that should not have been included in its reimbursement request. Specifically, we found that DHS included a $395,000 payment for which it received a refund from the vendor. In addition, we found that DHS included a payment for $460,368 twice within the supporting documentation it provided to FEMA for its reimbursement request. Context: During FY 2021-22, DHS received reimbursements for costs associated with the public health emergency totaling $154.4 million from the Disaster Grants?Public Assistance (Presidentially Declared Disasters) grant. We reviewed the supporting documentation for the two largest reimbursements and tested a selection of expenditures. Questioned Costs: $855,368 Effect: Because it received Disaster Grants?Public Assistance (Presidentially Declared Disasters) grant funding for inappropriate expenditure transactions, DHS was not in compliance with federal requirements. Cause: The inappropriate expenditure transactions we identified were included in the first large reimbursement request prepared by DHS, which was based on information provided by another state agency. At the time of this reimbursement request, DHS did not have procedures in place to identify duplicate or refunded payments within the data used to support the reimbursement request. DHS staff indicated that subsequent reimbursement requests were prepared using DHS queries from STAR, which is the State?s accounting system, that removed duplicated or refunded transactions. We did not identify issues in the other reimbursement request we reviewed. Recommendation: We recommend the Wisconsin Department of Health Services work with the federal government to resolve the $855,368 in unallowable costs we identified. Finding 2022-300: Disaster Grants?Public Assistance (Presidentially Declared Disasters)?Unallowable Costs COVID-19?Disaster Grants?Public Assistance (Presidentially Declared Disasters) (Assistance Listing number 97.036) Award Number Award Year 4650DR4520PA 2022 Questioned Costs: $855,368 Type of Finding: Noncompliance Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
2022-001 - ACTIVITIES ALLOWED OR UNALLOWED / ALLOWABLE COSTS/COST PRINCIPLES Program: ALN 84.425 Education Stabilization Fund, ESSER II - Formula Type: Material Weakness in Internal Control / Non-Compliance Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that payments were charged to the grant but were not authorized by the grant. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $104,101 Recommendation: We recommend that the District review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2022-001 - ACTIVITIES ALLOWED OR UNALLOWED / ALLOWABLE COSTS/COST PRINCIPLES Program: ALN 84.425 Education Stabilization Fund, ESSER II - Formula Type: Material Weakness in Internal Control / Non-Compliance Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that payments were charged to the grant but were not authorized by the grant. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $104,101 Recommendation: We recommend that the District review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2022-001 - ACTIVITIES ALLOWED OR UNALLOWED / ALLOWABLE COSTS/COST PRINCIPLES Program: ALN 84.425 Education Stabilization Fund, ESSER II - Formula Type: Material Weakness in Internal Control / Non-Compliance Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that payments were charged to the grant but were not authorized by the grant. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $104,101 Recommendation: We recommend that the District review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2022-001 - ACTIVITIES ALLOWED OR UNALLOWED / ALLOWABLE COSTS/COST PRINCIPLES Program: ALN 84.425 Education Stabilization Fund, ESSER II - Formula Type: Material Weakness in Internal Control / Non-Compliance Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that payments were charged to the grant but were not authorized by the grant. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $104,101 Recommendation: We recommend that the District review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.
2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.