Finding 1151096 (2021-007)

Significant Deficiency
Requirement
AB
Questioned Costs
$1
Year
2021
Accepted
2025-08-26
Audit: 364929
Organization: Virgin Islands Port Authority (VI)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The Authority improperly claimed $632,113 in payroll reimbursements, including $79,038 for non-eligible Marine division activities.
  • Impacted Requirements: This finding violates federal cost principles and internal control requirements under 2 CFR Section 200.303.
  • Recommended Follow-Up: The Authority should enhance internal controls to ensure compliance with federal regulations and accurate payroll cost allocation.

Finding Text

Finding Number: 2021-007 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Cost Principles Program: U.S. Department of Transportation COVID-19 Airport Improvement Program ALN: 20.106 Award #: 3-78-0001-043-2020 Award Period: 5/12/2020 – 5/12/2024 Criteria – Per the grant award, funds may be used to reimburse operational and maintenance expenses directly related to the Sponsor-owned and operated Airports, incurred no earlier than January 20, 2020. Further, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires the non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonable ensure compliance with Federal statutes, regulations, and other terms and conditions of the Federal award. Condition – During our testing of payroll expenditures incurred throughout the year, we noted for one pay period, the Authority sought and received reimbursement for payroll activities unrelated to Sponsor-owned and operated Airports. The total reimbursement amount of $632,113 exceeded the actual payroll expenditures for Sponsor-owned and operated airports, which totaled $553,075. The difference of $79,038 was related to the operations of the Authority’s Marine division. Cause – The Authority does not appear to have adequate policies and procedures to ensure compliance with applicable cost principles or to ensure that an appropriate level of review and approval is completed prior to charging costs to a federal program. Effect or Potential Effect – An ineffective control system for reviewing transactions to ensure that only allowable costs and allowable activities are allocated to federal programs can result in noncompliance with federal statutes, regulations, and the provisions of grant agreements, which could ultimately lead to disallowed costs for major programs. Questioned Costs – $79,038. Context – This is a condition identified per review of the Authority’s compliance with the specified requirements. The exception noted was not part of a statistically valid sample. Recommendation – We recommend that the Authority reevaluate and improve internal controls to ensure adherence to federal regulations related to the fiscal administrative requirements for expending and accounting for payroll, and to ensure proper and accurate allocation of payroll costs.   Views of Responsible Officials - The Authority concurs with the auditor’s findings and recommendations. The Authority will implement measures to ensure proper monitoring and review are completed prior to charging costs to a federal program. The planned corrective actions are presented in the Authority’s Corrective Action Plan, which is attached as Appendix B.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 574651 2021-006
    Material Weakness Repeat
  • 574652 2021-008
    Significant Deficiency Repeat
  • 574653 2021-009
    Material Weakness Repeat
  • 574654 2021-007
    Significant Deficiency
  • 574655 2021-008
    Significant Deficiency Repeat
  • 574656 2021-009
    Material Weakness Repeat
  • 574657 2021-010
    Material Weakness
  • 574658 2021-011
    Material Weakness Repeat
  • 1151093 2021-006
    Material Weakness Repeat
  • 1151094 2021-008
    Significant Deficiency Repeat
  • 1151095 2021-009
    Material Weakness Repeat
  • 1151097 2021-008
    Significant Deficiency Repeat
  • 1151098 2021-009
    Material Weakness Repeat
  • 1151099 2021-010
    Material Weakness
  • 1151100 2021-011
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
20.106 Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and Covid-19 Airports Programs $20.49M
11.307 Economic Adjustment Assistance $9.42M
20.933 National Infrastructure Investments $3.55M
97.090 Law Enforcement Officer Reimbursement Agreement Program $211,021
97.072 National Explosives Detection Canine Team Program $154,358
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $126,623