Finding Reference Number: 2024-021 NH Department of Energy Low Income Home Energy Assistance (Assistance Listing #93.568) Federal Award Numbers: 2301NHLIEA, 2401NHLIEA Federal Award Year: 2023, 2024 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-015 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity must: • Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); • Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required through the terms and conditions of the award, subaward monitoring must include following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states 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. Condition As part of the Low-Income Home Energy Assistance program (LIHEAP), the New Hampshire Department of Energy (the Department) enters into grant agreements with local entities to provide services related to the eligibility determination process for the LIHEAP program (including the calculation of participant benefits) and payment of benefits to fuel providers. During the year ended June 30, 2024, $38,545,693 was passed through to subrecipients. As part of our testwork over the subrecipient monitoring process, we identified the following: A. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for each of the 4 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) b. Identification of whether the award is R&D B. The data that is used to compile the Annual Report on Households Assisted by LIHEAP is obtained from case data that is reported to the New Hampshire Department of Energy (the Department) from its subrecipients as the Department has entered into grant agreements with third parties who are responsible for the eligibility determination and benefit payment process. The Annual Report on Households Assisted by LIHEAP contains data that is specific to benefits paid to eligible participants. As part of our subrecipient monitoring testwork, we were unable to verify that the Department had performed any monitoring procedures over the data provided by each subrecipient to ensure that the data reported within the annual report was complete and accurate. Cause The cause of the condition found was primarily due to insufficient documented subrecipient policies and procedures to ensure that award information is appropriately communicated and that there is appropriate monitoring procedures performed over the completeness and accuracy of the data submitted by the subrecipient utilized to compile federal reports. Effect The effect of the condition found is that the Department did not comply with section 2 CFR 200.332 (a) and 2 CFR 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend that the Department formalize, policies and procedures and implement the necessary internal controls to ensure that all required award identification information is communicated to subrecipients and over the monitoring of data submitted by subrecipients to be used in the Annual Report on Households Assisted by LIHEAP to ensure that the report is complete and accurate. View of Responsible Officials: Management concurs with the finding above.
2024-009 – Indirect Costs Federal Agency: Various Federal Program Title: Research and Development Cluster Federal Assistance Listing Number: 10.216 Federal Award Identification Number and Year: Various Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: In accordance with 2 CFR section 200.414(c), negotiated indirect cost rates must be accepted by all Federal agencies. A Federal agency may use a rate different from the negotiated rate for either a class of Federal awards or a single Federal award only when required by Federal statute or regulation, or when approved by the awarding Federal agency in accordance with paragraph (c)(3) of this section. Condition: An incorrect indirect cost rate was used when calculating indirect costs. Questioned Costs: $38,449 Context: During our testing of indirect costs, three out of a sample of 40 used a rate of 46% instead of the rate stated in the grant of 30%. Cause: Oversight by the individual responsible for completing the indirect cost calculations. Effect: Overstatement of indirect costs. Repeat Finding: No. Recommendation: We recommend the University establish a policy to review the specific indirect cost rates in the grants with the calculation being performed to ensure the correct rate is being used. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-009 – Indirect Costs Federal Agency: Various Federal Program Title: Research and Development Cluster Federal Assistance Listing Number: 10.216 Federal Award Identification Number and Year: Various Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: In accordance with 2 CFR section 200.414(c), negotiated indirect cost rates must be accepted by all Federal agencies. A Federal agency may use a rate different from the negotiated rate for either a class of Federal awards or a single Federal award only when required by Federal statute or regulation, or when approved by the awarding Federal agency in accordance with paragraph (c)(3) of this section. Condition: An incorrect indirect cost rate was used when calculating indirect costs. Questioned Costs: $38,449 Context: During our testing of indirect costs, three out of a sample of 40 used a rate of 46% instead of the rate stated in the grant of 30%. Cause: Oversight by the individual responsible for completing the indirect cost calculations. Effect: Overstatement of indirect costs. Repeat Finding: No. Recommendation: We recommend the University establish a policy to review the specific indirect cost rates in the grants with the calculation being performed to ensure the correct rate is being used. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-009 – Indirect Costs Federal Agency: Various Federal Program Title: Research and Development Cluster Federal Assistance Listing Number: 10.216 Federal Award Identification Number and Year: Various Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: In accordance with 2 CFR section 200.414(c), negotiated indirect cost rates must be accepted by all Federal agencies. A Federal agency may use a rate different from the negotiated rate for either a class of Federal awards or a single Federal award only when required by Federal statute or regulation, or when approved by the awarding Federal agency in accordance with paragraph (c)(3) of this section. Condition: An incorrect indirect cost rate was used when calculating indirect costs. Questioned Costs: $38,449 Context: During our testing of indirect costs, three out of a sample of 40 used a rate of 46% instead of the rate stated in the grant of 30%. Cause: Oversight by the individual responsible for completing the indirect cost calculations. Effect: Overstatement of indirect costs. Repeat Finding: No. Recommendation: We recommend the University establish a policy to review the specific indirect cost rates in the grants with the calculation being performed to ensure the correct rate is being used. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-009 – Indirect Costs Federal Agency: Various Federal Program Title: Research and Development Cluster Federal Assistance Listing Number: 10.216 Federal Award Identification Number and Year: Various Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: In accordance with 2 CFR section 200.414(c), negotiated indirect cost rates must be accepted by all Federal agencies. A Federal agency may use a rate different from the negotiated rate for either a class of Federal awards or a single Federal award only when required by Federal statute or regulation, or when approved by the awarding Federal agency in accordance with paragraph (c)(3) of this section. Condition: An incorrect indirect cost rate was used when calculating indirect costs. Questioned Costs: $38,449 Context: During our testing of indirect costs, three out of a sample of 40 used a rate of 46% instead of the rate stated in the grant of 30%. Cause: Oversight by the individual responsible for completing the indirect cost calculations. Effect: Overstatement of indirect costs. Repeat Finding: No. Recommendation: We recommend the University establish a policy to review the specific indirect cost rates in the grants with the calculation being performed to ensure the correct rate is being used. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-009 – Indirect Costs Federal Agency: Various Federal Program Title: Research and Development Cluster Federal Assistance Listing Number: 10.216 Federal Award Identification Number and Year: Various Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: In accordance with 2 CFR section 200.414(c), negotiated indirect cost rates must be accepted by all Federal agencies. A Federal agency may use a rate different from the negotiated rate for either a class of Federal awards or a single Federal award only when required by Federal statute or regulation, or when approved by the awarding Federal agency in accordance with paragraph (c)(3) of this section. Condition: An incorrect indirect cost rate was used when calculating indirect costs. Questioned Costs: $38,449 Context: During our testing of indirect costs, three out of a sample of 40 used a rate of 46% instead of the rate stated in the grant of 30%. Cause: Oversight by the individual responsible for completing the indirect cost calculations. Effect: Overstatement of indirect costs. Repeat Finding: No. Recommendation: We recommend the University establish a policy to review the specific indirect cost rates in the grants with the calculation being performed to ensure the correct rate is being used. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-009 – Indirect Costs Federal Agency: Various Federal Program Title: Research and Development Cluster Federal Assistance Listing Number: 10.216 Federal Award Identification Number and Year: Various Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: In accordance with 2 CFR section 200.414(c), negotiated indirect cost rates must be accepted by all Federal agencies. A Federal agency may use a rate different from the negotiated rate for either a class of Federal awards or a single Federal award only when required by Federal statute or regulation, or when approved by the awarding Federal agency in accordance with paragraph (c)(3) of this section. Condition: An incorrect indirect cost rate was used when calculating indirect costs. Questioned Costs: $38,449 Context: During our testing of indirect costs, three out of a sample of 40 used a rate of 46% instead of the rate stated in the grant of 30%. Cause: Oversight by the individual responsible for completing the indirect cost calculations. Effect: Overstatement of indirect costs. Repeat Finding: No. Recommendation: We recommend the University establish a policy to review the specific indirect cost rates in the grants with the calculation being performed to ensure the correct rate is being used. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-009 – Indirect Costs Federal Agency: Various Federal Program Title: Research and Development Cluster Federal Assistance Listing Number: 10.216 Federal Award Identification Number and Year: Various Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: In accordance with 2 CFR section 200.414(c), negotiated indirect cost rates must be accepted by all Federal agencies. A Federal agency may use a rate different from the negotiated rate for either a class of Federal awards or a single Federal award only when required by Federal statute or regulation, or when approved by the awarding Federal agency in accordance with paragraph (c)(3) of this section. Condition: An incorrect indirect cost rate was used when calculating indirect costs. Questioned Costs: $38,449 Context: During our testing of indirect costs, three out of a sample of 40 used a rate of 46% instead of the rate stated in the grant of 30%. Cause: Oversight by the individual responsible for completing the indirect cost calculations. Effect: Overstatement of indirect costs. Repeat Finding: No. Recommendation: We recommend the University establish a policy to review the specific indirect cost rates in the grants with the calculation being performed to ensure the correct rate is being used. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Awards to Subrecipients Criteria – The Uniform Guidance, Part 200.332 states, “All pass-through entities must: ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.” Required information includes identification of whether the award is research and development and the indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. Condition – For five out of six subawards, the Department did not include identification of whether the award is research and development or indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. These contracts also did not include the subrecipient’s Unique Entity Identifiers, nor the Federal Award Date. Cause – At the time the tested agreements were established, the Department had not established policies and procedures to ensure all required information is included in the subaward to the subrecipients. Effect – The information required in the subaward to subrecipients would result in grantee’s not being aware of their current indirect cost rate allowance, or if the award was for R&D purposes. Recommendation – The Department should establish policies and procedures to ensure all required information is included in the subaward to subrecipients as required by Uniform Guidance, Part 200.332. Response and Corrective Action Planned – Effective late fiscal year 2024; new sub-awards and pass thru grant agreements utilize a cover sheet to ensure all required elements listed in 2 CFR 200.332 are clearly included in the subaward agreements. Conclusion – Response accepted.
Awards to Subrecipients Criteria – The Uniform Guidance, Part 200.332 states, “All pass-through entities must: ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.” Required information includes identification of whether the award is research and development and the indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. Condition – For five out of six subawards, the Department did not include identification of whether the award is research and development or indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. These contracts also did not include the subrecipient’s Unique Entity Identifiers, nor the Federal Award Date. Cause – At the time the tested agreements were established, the Department had not established policies and procedures to ensure all required information is included in the subaward to the subrecipients. Effect – The information required in the subaward to subrecipients would result in grantee’s not being aware of their current indirect cost rate allowance, or if the award was for R&D purposes. Recommendation – The Department should establish policies and procedures to ensure all required information is included in the subaward to subrecipients as required by Uniform Guidance, Part 200.332. Response and Corrective Action Planned – Effective late fiscal year 2024; new sub-awards and pass thru grant agreements utilize a cover sheet to ensure all required elements listed in 2 CFR 200.332 are clearly included in the subaward agreements. Conclusion – Response accepted.
Awards to Subrecipients Criteria – The Uniform Guidance, Part 200.332 states, “All pass-through entities must: ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.” Required information includes identification of whether the award is research and development and the indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. Condition – For five out of six subawards, the Department did not include identification of whether the award is research and development or indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. These contracts also did not include the subrecipient’s Unique Entity Identifiers, nor the Federal Award Date. Cause – At the time the tested agreements were established, the Department had not established policies and procedures to ensure all required information is included in the subaward to the subrecipients. Effect – The information required in the subaward to subrecipients would result in grantee’s not being aware of their current indirect cost rate allowance, or if the award was for R&D purposes. Recommendation – The Department should establish policies and procedures to ensure all required information is included in the subaward to subrecipients as required by Uniform Guidance, Part 200.332. Response and Corrective Action Planned – Effective late fiscal year 2024; new sub-awards and pass thru grant agreements utilize a cover sheet to ensure all required elements listed in 2 CFR 200.332 are clearly included in the subaward agreements. Conclusion – Response accepted.
Awards to Subrecipients Criteria – The Governor allocated Coronavirus State and Local Recovery Funds to the Department for Child Care Business Incentive to encourage and enable businesses and employer consortiums to build on-site childcare centers or partner with local and regional childcare services to renovate and expand. Health Careers Registered Apprenticeship 2.0 Grant was created to establish new or expand existing, high school-based and/or adult registered apprenticeship programs for health careers in nursing, emergency medical services, direct support care and behavioral health career pathways. The Healthy Childhood Environments: Child Care Challenge project was to create new childcare slots across the State and help communities improve their childcare options and bolster opportunities for Iowans to reenter the workforce. All the projects are designed to address childcare shortages and alleviate local childcare need. The Uniform Guidance, Part 200.332 states, “All pass-through entities must: ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.” Required information includes, in part, subrecipient's unique entity identifier, federal award identification number (FAIN), subaward budget period start and end date, identification of whether the award is research and development and the indirect cost rate for the federal award (including if the de minimis rate is charged) per Part 200.414. Condition – For the subawards provided, the Department did not include the identification of whether the award is research and development and the indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. Cause – The Department has not established policies and procedures to ensure all required information is included in the subaward to the subrecipients. Effect – The information required in the subaward to subrecipients was not included due to the lack of policies and procedures. Recommendation – The Department should establish policies and procedures to ensure all required information is included in the subaward to subrecipients as required by Uniform Guidance, Part 200.332. Response and Corrective Action Planned – Effective August 2023; new sub-awards and pass thru grant agreements have elements specified in the respective agreement as required by Uniform Guidance, Part 200.332. In addition, Iowa Workforce Development is in the process of reaching out to grantees whose awards did not clearly state that the specified award is research and development, and that there will be no indirect costs assumed for reimbursement, as this was assumed given the nature of the projects as well as discussions that were had during the awarding process. Conclusion – Response accepted.
Finding 2024-004: Unallowable Costs / Cash Management (Material Weakness) Information on the Federal Programs: Assistance Listing Number 98.001 Criteria: According to Uniform Guidance (2 CFR 200.305(b)), Federal funds must be managed in a way that minimizes the time elapsing between the transfer of funds and the Organization’s disbursement of those funds for program purposes. Additionally, internal controls over cash management should ensure that all drawdowns are approved by designated personnel to prevent improper or premature use of Federal funds. Furthermore, per 2 CFR 200.414(c), indirect costs may only be charged to a Federal program if an approved indirect cost rate or a direct cost allocation methodology is in place and if the Federal award allows for indirect cost recovery. Condition: During our review of Federal grant drawdowns, it was noted that several drawdowns were processed without obtaining the required internal approvals as outlined in Astraea's cash management policies and procedures. We also noted that several draws included indirect costs, despite the Federal award agreement explicitly prohibiting indirect cost recovery. While these costs were later removed and ultimately not charged to the Federal program, their inclusion initially led to an overdraw of funds exceeding the program’s actual needs. Furthermore, Astraea is carrying a large refundable advance balance. Cause: Astraea’s cash management procedures were not consistently followed, leading to missed approvals for certain drawdowns and delays in fund disbursement. Additionally, the lack of approval led to errors in charging indirect costs to the program.Effect: Drawdowns without proper internal approval increase the risk of non-compliance with Federal cash management requirements and could result in unauthorized or inaccurate fund usage. Additionally, charging unallowable indirect costs to the program resulted in noncompliance with Federal regulations. Furthermore, the delay in disbursing Federal funds increases the risk of noncompliance with cash management requirements, potentially resulting in interest liability. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: Finding 2023-005 Recommendation: Astraea should reinforce cash management controls by ensuring all Federal drawdowns obtain the appropriate internal approvals before processing. This can be achieved by implementing a checklist or automated workflow to verify compliance with approval requirements. Astraea should also strengthen internal controls over cost allocation to prevent unallowable indirect charges. Additionally, we recommend Astraea implement procedures to ensure that Federal funds are disbursed promptly in accordance with 2 CFR 200.305 to avoid undue delays.
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 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not adequately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: The non-Federal entity must: (a) 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total federal awards expended for loan or loan guarantee programs in the schedule; and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2024 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur, and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Federal awards, which prevented the City from meeting the March 31, 2025 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.