Finding Text
Assistance Listing Number, Federal Agency, and Program Name - 12.300, Office of Naval Research, Research and Development Cluster
Federal Award Identification Number and Year - N0001 19 S F006
Finding Type - Significant deficiency
Repeat Finding - Yes
2020 001
Criteria - Per 2 CFR 430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100 percent of compensated activities.
Condition - The budgeting and billing methods used did not impose limitations, as required by the terms and provisions of the grant agreement.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Not applicable
Context - Originally identified in 2020, the Organization initially charged amounts to the grant that exceeded actual compensation costs. This was resolved in late 2021, and, as a result, the Organization did not submit reimbursement requests to the Office of Naval Research until a revised budget was approved and correct billing practices put in place.
Cause and Effect - The Organization did not have the internal controls in place to identify this error and was unable to correct it until a third party consultant was hired to correct the error.
Recommendation - Management should implement controls to ensure expenditures charged to the grant accurately reflect the work performed and comply with terms and provisions of the grant agreement.
Views of Responsible Officials and Corrective Action Plan - The Organization acknowledges this finding. Billing for 2021 and 2022 was held once the error was discovered to avoid exacerbating the problem. The amount that was overbilled was returned to the agency by reducing the amount of reimbursement requests for 2021. All of the revised billings and reimbursement were completed in November 2022. Management has also implemented controls to ensure expenditures charged to the grant accurately reflect the work performed and comply with terms and provisions of the grant agreement and appointed outside consultants to ensure appropriate billing and indirect cost rate calculations.