Core Issue: The Cooperative submitted costs for reimbursement that were incurred before the authorized period of performance, violating grant agreement terms.
Impacted Requirements: All expenditures must be made within the specified period of performance to be considered allowable under federal program 97.047.
Recommended Follow-Up: Implement internal controls to verify that all invoice amounts are within the authorized period before submitting for reimbursement.
Finding Text
Identification of the federal program: 97.047 – Building Resilient Infrastructure and Communities (BRIC)
Noncompliance with period of performance and significant deficiency in internal controls
Criteria:
According to the grant agreement, all funds must be expended only within the authorized period of performance as
outlined in the agreement. Any costs incurred outside this timeframe are considered unallowable.
Condition:
The Cooperative did not have proper review processes in place to ensure all amounts for an invoice fall within the
period of performance.
Cause:
The Cooperative did not ensure all expenditures submitted for reimbursement fell within the period of performance.
Effect:
The Cooperative submitted costs for reimbursement that occurred prior to the period of performance starting.
Questioned Costs:
$11,537
Recommendations:
The Cooperative should establish and follow internal controls policies to ensure all amounts within an invoice are
within the period of performance prior to the approval of submission for reimbursement.
Views of responsible officials:
This expenditure being outside of the period of award was discovered immediately following the submission of
request for reimbursement #2 and subsequently deducted from request for reimbursement #3. The period of
performance was not easily identifiable and different agencies provided different date ranges. Moving forward we
will get the period of performance in writing.
Categories
Questioned CostsAllowable Costs / Cost PrinciplesCash ManagementPeriod of PerformanceSignificant DeficiencyInternal Control / Segregation of Duties