2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must: (1) List individual Federal programs by 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. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. (6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system. Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs' compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must: (1) List individual Federal programs by 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. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. (6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system. Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs' compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must: (1) List individual Federal programs by 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. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. (6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system. Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs' compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must: (1) List individual Federal programs by 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. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. (6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system. Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs' compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must: (1) List individual Federal programs by 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. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. (6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system. Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs' compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must: (1) List individual Federal programs by 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. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. (6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system. Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs' compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2022-005 Indirect Cost Allocations - Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Program: Research and Development Cluster (ALN 47.041-Engineering, Award 1940055, Award Period 9/1/19 – 8/31/22) Federal Agency: National Science Foundation Criteria: Program costs for allocation of indirect costs were based on percentage of total costs at year end and not allocated based on specific allocations of costs incurred and approved in a timely manner as required by 2 CFR 200.414. Condition: Our testing noted that program charges include journal entries to allocate indirect costs without necessary review and approvals to ensure allowability of the costs to program activities. Cause: The Organization lacks written policies, approval procedures and documentation to allocate indirect costs to the program. Effect: The Organization is not compliant with 2 CFR 2 CFR 200.414 which requires accurate, and complete disclosure of financial results including the allocation of approved and identified actual indirect costs incurred to the program in accordance with 2 CFR 200.414. Without a policy of reviewing and approving indirect costs on a regular basis, there is a risk that unallowable costs are allocated to the program. Identification as a repeat finding, if applicable: The finding is a repeat of Finding 2021-006 in the prior year. Recommendation: We recommend the Organization establish policy and procedures to identify and approve allowable indirect costs chargeable to the program on a monthly basis and report this allocation in the accounting ledger separately from the general expenses of the company. Response: The Organization will allocate indirect costs to program costs based on incurred costs. Monthly allocations will be approved by the program administrator and separately reported in the general ledger. Questioned Costs: $78,400 – This is the amount of indirect costs charged to the program.
Criteria: Title 2 of the Code of Federal Regulations (2 CFR), Part 200, Subpart E defines and discusses the federal cost principles that apply to federal awards administered by nonprofit organizations. The applicable sections of these cost principes are as follows: • 2 CFR 200.403 Factors affecting allowability of costs • 2 CFR 200.404 Reasonable costs • 2 CFR 200.405 Allocable costs • 2 CFR 200.413 Direct costs • 2 CFR 200.414 Indirect (F&A) costs Condition: The following were noted as related to compliance with allowable costs, cost allocation and federal cost principles: • Internal control on time spent by employees related to administrative functions or other indirect cost activities has not been properly designed or implemented. • All employee time, including employees and professional services contractors are being recorded directly to programs. Time spent on indirect activities is not being properly identified or properly allocated to programs. • A portion of time of the Operations Manager (Chief Executive of the Organization) is spent related to administrative time or other indirect cost activities. However, none of that time has been identified or charged as indirect costs. • The time card for the Operations Manager (Chief Executive of the Organization) is not reviewed or approved by a board member or other senior executive of the Organization. • The accounting services of AIRS is being provided by a third-party outsourced accountant. The costs related to these services were improperly recorded as direct personnel costs to the program rather than properly classified as indirect costs. • Payroll taxes, employee benefits and other allowable employee related expenses were allocated to the program in a manner that does not accurately reflect the relative benefits received. These costs were allocated to the program as a percentage of total payroll costs, however, the percentage used exceeds that actual percentage of these costs as a percentage of total payroll costs. • A reasonable, consistent and uniform cost allocation methodology has not been properly designed or implemented. Costs that benefit both federal programs, non-federal programs and indirect costs are not being allocated properly across and to federal programs, non-federal programs and indirect costs in a reasonable, consistent and uniform manner. • Certain direct costs charged to the program were not based on actual costs incurred and the amounts charged were not adequately supported. • Indirect costs were not properly identified and segregated from direct costs. • Allowable indirect costs were not charged to the federal program. Cause: AIRS accounting staff and senior management do not appear to have a full and complete understanding of Uniform Guidance or of the applicable federal cost principles. Management has not properly applied the applicable federal costs principles in 2 CFR, Part 200, Subpart E to the costs charged to the federal program. Effect: Payroll costs and allowable employee related expenses, certain direct costs, allocable direct costs and indirect costs were not properly charged to the federal program. In order to estimate the questioned costs, the auditor, with the assistance of management, developed a costs allocation methodology that charges costs to the federal program in a reasonable, consistent and uniform manner in compliance with the costs principles contained in 2 CFR, Part 200, Subpart E. The primarily characteristics of this methodology are as follows: • Based upon discussions with management, review of the job description, roles and responsibilities of the Operations Manager and using prior experience and comparison to similar nonprofit organizations; an estimate of the percentage of time spent by the Operations Manager related to administration and other indirect activities was developed. • The time for the outsourced accounting services provider was removed from direct personnel costs and charged to indirect costs. • After the above revisions were made, the auditor assisted management in reallocating payroll costs across all federal and nonfederal programs and to indirect costs in a reasonable, consistent and uniform manner. • Allowable payroll taxes, benefits and other employee related expense charges were estimated using the actual percentage of these expenses as a percentage of total allowable payroll costs. • Non-allocable direct costs were charged to the program at the actual amount of those costs incurred. • Allocable direct costs charges were estimated by allocating those costs to the federal program on the basis of allowable payroll costs charged to program as a percentage of total allowable payroll costs (percentage of payroll methodology). This methodology is in compliance with the requirements of 2 CFR 200.405 and appears to produce a result that reasonably estimates the proportional benefit of these costs to all federal and non-federal programs, and to indirect cost activities. • Indirect costs were estimated and charged to the program using the 10% de minimis indirect cost rate as defined in 2 CFR 200.414. Questioned Costs: Using the methodology described above, the auditor has estimated total federal expenditures allowable to the program of $247,119. However, AIRS has charged federal expenditures of $272,781 to the program. Therefore, the estimated questioned costs related to this program are $25,662. Repeat Finding from Prior Year: No Recommendation: Senior management and accounting personnel should create procedures to ensure that direct program costs are charged at the actual amounts incurred, develop a payroll cost allocation methodology, and an allocable direct cost allocation methodology that ensures that costs are reasonably, consistently and uniformly charged to and across all federal and non-federal programs and to indirect costs relative to the proportional benefit of those costs, and in compliance with the applicable federal cost principles in 2 CFR, Part 200, Subpart E. Management and the board should consider providing senior management, accounting personnel and applicable program personnel additional training and education related to the proper application of and compliance with the federal costs principles as defined in 2 CFR, Part 200, Subpart E. Management and the board may also want to consider engaging a third-party CPA or other accounting professional who has extensive prior skills, knowledge and experience related to Uniform Guidance and federal cost principles. Views of Responsible Officials: Management concurs with this audit finding.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
2021-003 – ALLOWABLE COSTS/COST PRINCIPLES-PAYROLL DOCUMENTATION (Continued) Federal Program Information: Federal Agency Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s) Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001 W15QKN-20-1-1000 (C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. (3) In accordance with Department of Labor regulations implementing the Fair Labor Standards Act (FLSA) (29 CFR part 516), charges for the salaries and wages of nonexempt employees, in addition to the supporting documentation described in this section, must also be supported by records indicating the total number of hours worked each day. 2 CFR 200.313 stipulates the identification with the Federal award rather than the nature of the goods and services involved is the determining factor in distinguishing direct from indirect (F&A) costs of Federal awards. Typical costs charged directly to a Federal award are the compensation of employees who work on that award, their related fringe benefit costs, the costs of materials and other items of expense incurred for the Federal award. If directly related to a specific award, certain costs that otherwise would be treated as indirect costs may also be considered direct costs. 2 CFR 200.414 stipulates that because of the diverse characteristics and accounting practices of nonprofit organizations, it is not possible to specify the types of cost which may be classified as indirect (F&A) cost in all situations. Identification with a Federal award rather than the nature of the goods and services involved is the determining factor in distinguishing direct from indirect (F&A) costs of Federal awards. However, typical examples of indirect (F&A) cost for many nonprofit organizations may include depreciation on buildings and equipment, the costs of operating and maintaining facilities, and general administration and general expenses, such as the salaries and expenses of executive officers, personnel administration, and accounting. SECTION III – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued) 2021-003 – ALLOWABLE COSTS/COST PRINCIPLES-PAYROLL DOCUMENTATION (Continued) Federal Program Information: Federal Agency Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s) Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001 W15QKN-20-1-1000 Condition: All employees paid with federal funds are paid a fixed salary pursuant to an employment contract established prior to the calendar year. Estimates for salaries were made prior to the services being performed. However, there was a lack of documentation, which substantiates that the payroll charged was accurate, allowable and properly allocated. Furthermore, there was no documentation of days or hours worked per day in accordance with federal guidelines. Officials recorded all personnel costs as indirect (which is consistent with the treatment of these expenses in prior years) expenses. However, the budget award document indicates a large portion of personnel costs to be classified as direct charges. Questioned Costs: Unknown. Context: Salaries and related fringe benefits of $576,127 were expended under the federal award. Total federal expenditures listed on the Schedule of Federal Awards was $6,267,848. Cause: Internal controls and procedures related to the payroll documentation were not effectively designed or performed. Effect: National Center for the Advancement of STEM Education, Inc. is not in compliance with the documentation requirements related to salaries and wages. Recommendation: We recommend that management implement policies and procedures to ensure that documentation of salaries and wages are maintained in a manner consistent with federal requirements. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
Criteria: Title 2 of the Code of Federal Regulations (2 CFR), Part 200, Subpart E defines and discusses the federal cost principles that apply to federal awards administered by nonprofit organizations. The applicable sections of these cost principes are as follows: • 2 CFR 200.403 Factors affecting allowability of costs • 2 CFR 200.404 Reasonable costs • 2 CFR 200.405 Allocable costs • 2 CFR 200.413 Direct costs • 2 CFR 200.414 Indirect (F&A) costs Condition: The following were noted as related to compliance with allowable costs, cost allocation and federal cost principles: • Internal control on time spent by employees related to administrative functions or other indirect cost activities has not been properly designed or implemented. • All employee time, including employees and professional services contractors are being recorded directly to programs. Time spent on indirect activities is not being properly identified or properly allocated to programs. • A portion of time of the Operations Manager (Chief Executive of the Organization) is spent related to administrative time or other indirect cost activities. However, none of that time has been identified or charged as indirect costs. • The time card for the Operations Manager (Chief Executive of the Organization) is not reviewed or approved by a board member or other senior executive of the Organization. • The accounting services of AIRS is being provided by a third-party outsourced accountant. The costs related to these services were improperly recorded as direct personnel costs to the program rather than properly classified as indirect costs. • Payroll taxes, employee benefits and other allowable employee related expenses were allocated to the program in a manner that does not accurately reflect the relative benefits received. These costs were allocated to the program as a percentage of total payroll costs, however, the percentage used exceeds that actual percentage of these costs as a percentage of total payroll costs. • A reasonable, consistent and uniform cost allocation methodology has not been properly designed or implemented. Costs that benefit both federal programs, non-federal programs and indirect costs are not being allocated properly across and to federal programs, non-federal programs and indirect costs in a reasonable, consistent and uniform manner. • Certain direct costs charged to the program were not based on actual costs incurred and the amounts charged were not adequately supported. • Indirect costs were not properly identified and segregated from direct costs. • Allowable indirect costs were not charged to the federal program. Cause: AIRS accounting staff and senior management do not appear to have a full and complete understanding of Uniform Guidance or of the applicable federal cost principles. Management has not properly applied the applicable federal costs principles in 2 CFR, Part 200, Subpart E to the costs charged to the federal program. Effect: Payroll costs and allowable employee related expenses, certain direct costs, allocable direct costs and indirect costs were not properly charged to the federal program. In order to estimate the questioned costs, the auditor, with the assistance of management, developed a costs allocation methodology that charges costs to the federal program in a reasonable, consistent and uniform manner in compliance with the costs principles contained in 2 CFR, Part 200, Subpart E. The primarily characteristics of this methodology are as follows: • Based upon discussions with management, review of the job description, roles and responsibilities of the Operations Manager and using prior experience and comparison to similar nonprofit organizations; an estimate of the percentage of time spent by the Operations Manager related to administration and other indirect activities was developed. • The time for the outsourced accounting services provider was removed from direct personnel costs and charged to indirect costs. • After the above revisions were made, the auditor assisted management in reallocating payroll costs across all federal and nonfederal programs and to indirect costs in a reasonable, consistent and uniform manner. • Allowable payroll taxes, benefits and other employee related expense charges were estimated using the actual percentage of these expenses as a percentage of total allowable payroll costs. • Non-allocable direct costs were charged to the program at the actual amount of those costs incurred. • Allocable direct costs charges were estimated by allocating those costs to the federal program on the basis of allowable payroll costs charged to program as a percentage of total allowable payroll costs (percentage of payroll methodology). This methodology is in compliance with the requirements of 2 CFR 200.405 and appears to produce a result that reasonably estimates the proportional benefit of these costs to all federal and non-federal programs, and to indirect cost activities. • Indirect costs were estimated and charged to the program using the 10% de minimis indirect cost rate as defined in 2 CFR 200.414. Questioned Costs: Using the methodology described above, the auditor has estimated total federal expenditures allowable to the program of $247,119. However, AIRS has charged federal expenditures of $272,781 to the program. Therefore, the estimated questioned costs related to this program are $25,662. Repeat Finding from Prior Year: No Recommendation: Senior management and accounting personnel should create procedures to ensure that direct program costs are charged at the actual amounts incurred, develop a payroll cost allocation methodology, and an allocable direct cost allocation methodology that ensures that costs are reasonably, consistently and uniformly charged to and across all federal and non-federal programs and to indirect costs relative to the proportional benefit of those costs, and in compliance with the applicable federal cost principles in 2 CFR, Part 200, Subpart E. Management and the board should consider providing senior management, accounting personnel and applicable program personnel additional training and education related to the proper application of and compliance with the federal costs principles as defined in 2 CFR, Part 200, Subpart E. Management and the board may also want to consider engaging a third-party CPA or other accounting professional who has extensive prior skills, knowledge and experience related to Uniform Guidance and federal cost principles. Views of Responsible Officials: Management concurs with this audit finding.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.
Federal Agency: U.S. Department of Interior Federal Program Name: National Park Service Conservation, Protection, Outreach, and Education (POE) Research and Development Cluster (RDC) Assistance Listing Number: 15.954 (POE) 15.608 and 15.945 (RDC) Award Period: June 2020 through August 2024 (POE) September 2019 through January 2024 (RDC) Statistically Valid Sample: No, and not intended to be a Statistically Valid Sample. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.414 Indirect Costs, any nonfederal entity that does not have current negotiated rate and elects the 10% de minimis rate must be applied to modified total direct costs (MTDC) indefinitely and in accordance with 2 CFR 200 UG, costs of compensation are allowable to the extent that they satisfy the specific requirements of the UG, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in accordance with the UG, Standards for Documentation of Personnel Expenses, when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, (iv) Encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the nonfederal entity's written policy; (v) Comply with the established accounting policies and practices of the nonfederal entity; and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition/Context: We noted instances where an indirect rate of 17.5 percent was charged to federal awards instead of the 10 percent de minimis rate approved in the budgets. Additionally, we were unable to obtain evidence of federal approval of a 1.8 percent administration fee charged to gross wages as follows: • POE & RDC - For 4 of the 4 months tested, 17.5 percent of indirect rate was charged to various awards instead of the 10 percent de minimis rate. • POE - For 12 of the 36 items tested, we noted a 1.8 percent administration fee charged to gross wages. • RDC - For 22 of the 22 items tested, we noted a 1.8 percent administration fee charged to gross wages. Questioned Costs: None greater than $25,000 per major program. Cause: Not aware of the requirements. Effect: Failure to comply with 2 CFR 200 can lead to improper payments charged to programs. Repeat Finding: No Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Views of Responsible Officials: There is no disagreement with the audit finding. See corrective action plan.