Finding Text
Criteria: 2 CFR section 200.53 defines improper payments as: "improper payment includes any payment to an ineligible party, any payment for an ineligible good or service, any duplicate payment." Further, the grant award agreement for this major program specifies that "the awardee certifies the work to be performed under this Agreement does not duplicate any work to be charged against any other contract, subcontract, or other source" and "Awardee shall not claim reimbursement for that portion of its obligations that are paid by another source of revenue."
Condition: The Auditor requested reimbursement requests for assistance listings 21.023 and 14.231 to reconcile expenditures to the final Schedule of Expenditures of Federal Awards and the underlying accounting records. The Auditor noted 15 instances of duplicate expenditures included in the two reimbursement requests. The Auditor noted both programs allowed for the expenditure type and the 15 expenditures were duplicated in the request for assistance listing 21.023 after being included in a request under assistance listing 14.231. Both reimbursement requests were funded by the awarding agency.
Questioned costs: The total of duplicated expenditures was $8,263.61. Based on sampling and extrapolation techniques, the likely questioned costs are in excess of $25,000.
Cause: CAC staff did not record the expenditures in a manner that allowed the individual costs to be allocable to only one program. Management tasked with reviewing the reimbursement request prior to submission did not properly review the expenditures to ensure they were allocated to only one specific program.
Effect: CAC was not in compliance with the requirements of 2 CFR 200 Subpart E, 2 CFR 200.53 and the terms and conditions of the grant agreement.
Recommendation: CAC management should revisit/establish controls to prevent allowable expenditures being allocated to more than one program. CAC management should research the question costs in an effort to determine amounts that should be reimbursed to the programs in question.
Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."