Finding 2023-004 Significant deficiency in internal controls over compliance related to allowable costs and cost principles compliance requirements. Federal Agency: All Awards reported on the schedule of expenditures of federal awards. Program Title: All Awards reported on the schedule of expenditures of federal awards. Assistance Listing Number: All Awards reported on the schedule of expenditures of federal awards. Award Number: All Awards reported on the schedule of expenditures of federal awards. Award Period: All Awards reported on the schedule of expenditures of federal awards. Criteria In accordance with 2 CFR 200.434, costs related to contributions and donations are unallowable costs. Condition/Context for Evaluation During the year ended June 30, 2023, we identified costs related to donations to other not-for-profit entities and organizations totaling approximately $143,350 that were included in the indirect cost pool. Effect or Potential Effect The Organization did not fully comply with the allowable cost principles as outlined in 2 CFR 200, Subpart E. As a result, the indirect cost pool for 2023 included unallowable costs. Questioned Costs Not determinable Cause The Organization’s internal controls did not ensure that all costs included in the indirect cost pool were allowable. Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization implement the necessary internal controls to ensure that only allowable costs are included in the indirect cost pool. Views of Responsible Officials of Auditee Management agrees with the finding and has provided the accompanying corrective action plan.
Finding 2023-004 Significant deficiency in internal controls over compliance related to allowable costs and cost principles compliance requirements. Federal Agency: All Awards reported on the schedule of expenditures of federal awards. Program Title: All Awards reported on the schedule of expenditures of federal awards. Assistance Listing Number: All Awards reported on the schedule of expenditures of federal awards. Award Number: All Awards reported on the schedule of expenditures of federal awards. Award Period: All Awards reported on the schedule of expenditures of federal awards. Criteria In accordance with 2 CFR 200.434, costs related to contributions and donations are unallowable costs. Condition/Context for Evaluation During the year ended June 30, 2023, we identified costs related to donations to other not-for-profit entities and organizations totaling approximately $143,350 that were included in the indirect cost pool. Effect or Potential Effect The Organization did not fully comply with the allowable cost principles as outlined in 2 CFR 200, Subpart E. As a result, the indirect cost pool for 2023 included unallowable costs. Questioned Costs Not determinable Cause The Organization’s internal controls did not ensure that all costs included in the indirect cost pool were allowable. Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization implement the necessary internal controls to ensure that only allowable costs are included in the indirect cost pool. Views of Responsible Officials of Auditee Management agrees with the finding and has provided the accompanying corrective action plan.
Finding 2023-004 Significant deficiency in internal controls over compliance related to allowable costs and cost principles compliance requirements. Federal Agency: All Awards reported on the schedule of expenditures of federal awards. Program Title: All Awards reported on the schedule of expenditures of federal awards. Assistance Listing Number: All Awards reported on the schedule of expenditures of federal awards. Award Number: All Awards reported on the schedule of expenditures of federal awards. Award Period: All Awards reported on the schedule of expenditures of federal awards. Criteria In accordance with 2 CFR 200.434, costs related to contributions and donations are unallowable costs. Condition/Context for Evaluation During the year ended June 30, 2023, we identified costs related to donations to other not-for-profit entities and organizations totaling approximately $143,350 that were included in the indirect cost pool. Effect or Potential Effect The Organization did not fully comply with the allowable cost principles as outlined in 2 CFR 200, Subpart E. As a result, the indirect cost pool for 2023 included unallowable costs. Questioned Costs Not determinable Cause The Organization’s internal controls did not ensure that all costs included in the indirect cost pool were allowable. Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization implement the necessary internal controls to ensure that only allowable costs are included in the indirect cost pool. Views of Responsible Officials of Auditee Management agrees with the finding and has provided the accompanying corrective action plan.
Finding 2022-008 Program Affected :66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 Federal Award Identification Number (FAIN): 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?200.434(c) specifies that "services donated or volunteered to the non-Federal entity ... may not be charged to the Federal award either as a direct or indirect cost." Condition and Context: In determining the population of payroll costs to test under the agreement, we determined the Organization charged $47,480 to the federal award related to unpaid volunteer time. The Organization imputed rates ranging from $35 to $50 per hour to volunteer labor and included this as reimbursable costs in billings to the federal agency. In our nonstatistical sample of 18 payroll transactions, we observed that 12 of them related to unpaid volunteers. Cause and Effect: The Organization does not have internal processes to properly identify costs related to the major federal program. The Organization does not have experience related to expending federal awards and did not properly obtain an understanding of what costs are allowable under the federal award. As a result, the Organization charged unallowable costs to the program. Questioned Costs: $47,480 Identification of Repeat Findings: N/A Recommendation: We recommend the Organization implement a tracking system to identify and report all expenditures of federal awards in compliance with the requirements of the Uniform Guidance. We recommend the Organization obtain training for employees and volunteers in order to gain an understanding of what costs are allowable under federal awards. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.
Finding 2022-008 Program Affected :66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 Federal Award Identification Number (FAIN): 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?200.434(c) specifies that "services donated or volunteered to the non-Federal entity ... may not be charged to the Federal award either as a direct or indirect cost." Condition and Context: In determining the population of payroll costs to test under the agreement, we determined the Organization charged $47,480 to the federal award related to unpaid volunteer time. The Organization imputed rates ranging from $35 to $50 per hour to volunteer labor and included this as reimbursable costs in billings to the federal agency. In our nonstatistical sample of 18 payroll transactions, we observed that 12 of them related to unpaid volunteers. Cause and Effect: The Organization does not have internal processes to properly identify costs related to the major federal program. The Organization does not have experience related to expending federal awards and did not properly obtain an understanding of what costs are allowable under the federal award. As a result, the Organization charged unallowable costs to the program. Questioned Costs: $47,480 Identification of Repeat Findings: N/A Recommendation: We recommend the Organization implement a tracking system to identify and report all expenditures of federal awards in compliance with the requirements of the Uniform Guidance. We recommend the Organization obtain training for employees and volunteers in order to gain an understanding of what costs are allowable under federal awards. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.
Finding No. 2022-001 Allowable Costs/Activities Allowed Fiscal Year: 2021-2022 Criteria Shuttered Venue Operators Grant (SVOG) was structured as grant program and therefore all recipients must implement their awards and spend funds consistent with the Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200 ? Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. However, when the program statute allows the use of SVOG award funds for a specific use beyond the scope of uses outlined in the Uniform Guidance, that use is allowed. All Shuttered Venue Operators Grant Program award funds expended must be eligible, allowable, allocable, and reasonable. Allowable costs are those costs that align with the statute and other basic frameworks. Fundraising is not an allowable use of SVOG funds and is further prohibited in line with 2 CFR 200.442. Costs of contributions and donations, including cash, property and services from non-Federal entity to other entities are also unallowable under 2 CFR 200.434. Condition The Organization used SVOG funds as contributions to other not-for-profit organizations. Questioned Costs $900 Cause The Organization did not comply with cost principles under 2 CFR Part 200, Subpart E section 200.434 Contributions and donations. Effect This finding falls under the audit area of Allowable costs and Activities Allowed. Costs that are not allowable under the grant were charged to the federal program. Material noncompliance for this assertion has been determined as an error rate greater than $61,000, individually and/or in aggregate. In evaluating the finding, auditors determined that the finding does not rise to the level of a significant deficiency or a material weakness. Recommendation We recommend that the Organization strengthen procedures to ensure they are following compliance requirements of Allowable costs/Activities allowed under the Uniform Guidance.
Finding No. 2022-001 Allowable Costs/Activities Allowed Fiscal Year: 2021-2022 Criteria Shuttered Venue Operators Grant (SVOG) was structured as grant program and therefore all recipients must implement their awards and spend funds consistent with the Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200 ? Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. However, when the program statute allows the use of SVOG award funds for a specific use beyond the scope of uses outlined in the Uniform Guidance, that use is allowed. All Shuttered Venue Operators Grant Program award funds expended must be eligible, allowable, allocable, and reasonable. Allowable costs are those costs that align with the statute and other basic frameworks. Fundraising is not an allowable use of SVOG funds and is further prohibited in line with 2 CFR 200.442. Costs of contributions and donations, including cash, property and services from non-Federal entity to other entities are also unallowable under 2 CFR 200.434. Condition The Organization used SVOG funds as contributions to other not-for-profit organizations. Questioned Costs $900 Cause The Organization did not comply with cost principles under 2 CFR Part 200, Subpart E section 200.434 Contributions and donations. Effect This finding falls under the audit area of Allowable costs and Activities Allowed. Costs that are not allowable under the grant were charged to the federal program. Material noncompliance for this assertion has been determined as an error rate greater than $61,000, individually and/or in aggregate. In evaluating the finding, auditors determined that the finding does not rise to the level of a significant deficiency or a material weakness. Recommendation We recommend that the Organization strengthen procedures to ensure they are following compliance requirements of Allowable costs/Activities allowed under the Uniform Guidance.