Finding Text
Federal Agency: Department of Justice
Federal Assistance Listing Numbers: 16.756, 16.726
Programs: Court Appointed Special Advocates, Juvenile Mentoring Program
Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in
order to be allowable under federal awards:
a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles.
b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items.
c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.
d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
g) Be adequately documented. See also §200.300 through §200.309.
h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that:
For Court Appointed Special Advocates:
• One of 60 transactions was partially charged in the incorrect fiscal period.
• One of 60 transactions underlying supporting documentation was not retained.
• 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs.
• 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries.
For the Juvenile Mentoring Program:
• One of 60 transactions lacked documentation of all required reviews and approvals.
• One of 60 transactions the incorrect allocation rate was utilized.
• One of 60 transactions underlying supporting documentation was not retained.
• 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries.
Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries).
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs.
Questioned Costs Court Appointed Special Advocates: Below reporting threshold.
Questioned Costs Juvenile Mentoring Program: Below reporting threshold.
Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403.
Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.