Finding 1155724 (2024-002)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
$1
Year
2024
Accepted
2025-09-26

AI Summary

  • Core Issue: Costs charged to federal awards must be allowable, reasonable, and incurred during the award period; however, an expense was charged prematurely for the VOCA grant.
  • Impacted Requirements: Compliance with 2 CFR § 200.403 and § 200.405 regarding timing and appropriateness of expenses.
  • Recommended Follow-Up: Review and reinforce policies on timing of cost obligations to ensure expenses align with when activities occur.

Finding Text

Criteria – According to 2 CFR § 200.403, 2 CFR § 200.405, and 2 CFR § 200.405, costs charged to federal awards must be allowable, reasonable, and allocable. Specifically, costs must be necessary and reasonable for the performance of the federal award, must conform to limitations and exclusions set forth in the cost principles, must be consistent with policies that apply uniformly to both federally financed and other activities, and costs must comply with the terms and conditions of the federal award. Federal funds must also only be used for expenditures incurred during the award period. Condition – During our review of expenditures charged to the Crime Victim Assistance (VOCA) grant, we noted that management charged an expense prior to the completion of the project. The expense was allowable under the grant, but the timing of the charge did not align with when the activity occurred. Cause – The premature charge occurred due to management attempting to use the remaining grant funds for that period before they expired. Questioned Cost Amount – Based on deviations noted in our testwork the projected likely questioned costs resulting in noncompliance are as follows: Crime Victim Assistance (VOCA), 16.575: $74,661. Effect – The Organization was not in compliance with the requirements listed above. Recommendation – We recommend the Organization review and reinforce policies regarding timing of cost obligations and expenditures and ensure expenses are recorded in alignment with when the related activity occurs. View of Responsible Officials – Management agrees with the finding. Corrective Action Plan – See attached corrective action plan from management.

Corrective Action Plan

All grant expenditures are reviewed by the Director of Grants and Compliance so that no grant expenditures are paid prior to services being received. The current Director of Grants and Compliance took over this position and procedure in November 2024. The material weakness occurred during a time of significant turnover among leadership staff at First Step, prior to the new DIrector of Grants and Compliance taking over this position and procedure. The Director of Grants and Compliance will have the responsibility to ensure the corrective action plan is in place.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1155720 2024-002
    Material Weakness Repeat
  • 1155721 2024-002
    Material Weakness Repeat
  • 1155722 2024-002
    Material Weakness Repeat
  • 1155723 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 Continuum of Care Program $34,470
16.588 Violence Against Women Formula Grants $33,972
93.558 Temporary Assistance for Needy Families $30,514
16.575 Crime Victim Assistance $29,387
97.024 Emergency Food and Shelter National Board Program $26,949
93.497 Family Violence Prevention and Services/ Sexual Assault/rape Crisis Services and Supports $21,406
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $14,748
14.218 Community Development Block Grants/entitlement Grants $4,000