Finding 1155730 (2024-001)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
$1
Year
2024
Accepted
2025-09-26
Audit: 368026

AI Summary

  • Core Issue: In-kind donations were incorrectly included as reimbursable costs in federal grant submissions.
  • Impacted Requirements: Federal guidelines prohibit charging donated services or property to the federal award as costs.
  • Recommended Follow-up: Reinforce understanding of federal grant rules regarding in-kind donations among program and accounting staff.

Finding Text

Finding #2024-001 – Other Noncompliance. Applicable federal program: U. S. Environmental Protection Agency, Passed through Texas Commission on Environmental Quality, Nonpoint Source Implementation Grants, Low Impact Development 2020, Assistance Listing #66.460, Contract period: 11/06/20 – 04/30/26, Contract number: 582-21-10148. Criteria: Allowable costs – Uniform Guidance, Subpart E Cost Principles, §200.434 states that the value of services and property donated to the recipient or subrecipient may not be charged to the federal award either as a direct or indirect cost. Condition and context: Under the terms of its agreement with the Texas Commission in Environmental Quality, HARC receives reimbursement for a percentage of the expenditures incurred in performance of the funded program. Donated services utilized in performance of the program were included in reimbursement submitted to the grantor. Cause: A lack of understanding that in-kind donations may not be charged to the federal award as reimbursable costs. Effect: As a result of not following federal grant requirements for the allowability of in-kind donations, unallowed costs were charged to the program. Questioned costs: $140,545. Recommendation: Re-emphasize to program and accounting personnel federal grant requirements for the allowability of in-kind donations. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

Finding #2024-001 – Other Noncompliance. Applicable federal program: U. S. Environmental Protection Agency, Passed through Texas Commission on Environmental Quality, Nonpoint Source Implementation Grants, Low Impact Development 2020, Assistance Listing #66.460, Contract period: 11/06/20 – 04/30/26, Contract number: 582-21-10148. Condition and context: Under the terms of its agreement with the Texas Commission in Environmental Quality, HARC receives reimbursement for a percentage of the expenditures incurred in performance of the funded program. Donated services utilized in performance of the program were included in reimbursement submitted to the grantor. Recommendation: Re-emphasize to program and accounting personnel federal grant requirements for the allowability of in-kind donations. Management’s response: Management concurs with the finding. This issue arose because the non-federal flow-through sponsor required certain in-kind cost share amounts to be invoiced as direct expenses, which conflicted with federal cost principles. It is important to note that while the questioned costs increased reported revenue for 2024, the program had unreimbursed expenditures. Corrective actions were implemented in the first half of 2025, including the hiring of new Grants and Contracts Management staff and strengthening of internal controls, to ensure compliance with federal requirements and prevent recurrence in future reporting. Responsible officer: Carmen Osier, Director of Business Operations. Estimated completion date: June 30, 2025.

Categories

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management HUD Housing Programs

Programs in Audit

ALN Program Name Expenditures
81.117 Energy Efficiency and Renewable Energy Information Dissemination, Outreach, Training and Technical Analysis/assistance $855,533
10.727 Inflation Reduction Act Urban & Community Forestry Program $715,944
81.041 State Energy Program $443,262
81.042 Weatherization Assistance for Low-Income Persons $297,795
81.086 Conservation Research and Development $234,227
66.959 Greenhouse Gas Reduction Fund: Solar for All $204,448
66.456 National Estuary Program $130,641
66.460 Nonpoint Source Implementation Grants $110,693
66.046 Climate Pollution Reduction Grants $67,710
81.255 Clean Energy Demonstrations $29,832
66.309 Surveys, Studies, Investigations, Training and Special Purpose Activities Relating to Environmental Justice $14,958