Finding Text
Federal Program/Award Identification: 11.307 COVID-19 Economic Adjustment Assistance – Economic Development Cluster Federal Award Project Number: 01-79-15100 Federal Award Project Year: 2019 Name of Federal Agency: United States Department of Commerce Name of the Applicable Pass-Through Entity: N/A Criteria: The Organization is required to comply with all terms and conditions of the grant agreement with the Revolving Loan Fund (RLF) Award granted by the U.S. Department of Commerce, Economic Development Administration (EDA). Per the Uniform Guidance (2 CFR section 200.414(f), recipients that do not have a current Federal negotiated indirect cost rate may elect to charge a de minimis rate up to 10 percent of modified total direct costs (MTDC). MTDC excludes capital expenditures including revolving loan fund capital. Condition: Management’s requests for reimbursement of indirect costs were not based on 10% of allowable modified total direct costs (MTDC). Reimbursements submitted were based on the amount included in the authorized budget from the EDA but not in accordance with the Uniform Guidance requirements for a de minimis indirect cost rate. Cause: The Organization is a small entity with limited resources to ensure all grant requirements are met. The Organization believed the calculation was allowed based on verbal conversations with the EDA representatives, but it was never documented in writing. Effect or Potential Effect: The Organization could have recognized revenue for indirect costs in excess of what was allowable under the Uniform Guidance. Questioned Costs: None Context: UHY requested that management calculate its indirect cost reimbursement under the requirements of Uniform Guidance and compare the amount paid by EDA to the calculation. The results of the calculation indicated that the Organization had not collected in excess of what it was entitled to, therefore, no questioned costs were identified. Recommendation: Management should implement a process to ensure the calculation of indirect costs charged against the EDA grant are in accordance with the Uniform Guidance and exclude any costs that are not allowed to be included in the MTDC. Views of Responsible Officials and Planned Corrective Action: See “Management’s Response and Corrective Action” plan section.