Finding 1157448 (2024-003)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
$1
Year
2024
Accepted
2025-09-30

AI Summary

  • Core Issue: The organization used an expired indirect cost rate in its grant application, leading to potential compliance risks.
  • Impacted Requirements: Must adhere to 2 CFR 200.403 for allowable costs and 2 CFR 200.414 for indirect cost rates.
  • Recommended Follow-Up: Obtain a current negotiated indirect cost rate and implement controls to monitor rate expirations before future budget submissions.

Finding Text

Identification of the federal program: Federal grantor: United States Department of Health and Human Services (HHS) Assistance Listing No.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.403 costs must be allowable; 2 CFR 200.405 allocable; and indirect costs must follow 2 CFR 200.414 and Appendix IV to Part 200 (nonprofit rate determination). Entities without a current negotiated rate may elect the 10% de minimis rate (2 CFR 200.414(f)). HHS adopts these requirements at 45 CFR Part 75. Condition: The organization applied and included an expired provisional indirect cost rate in its HHS grant application and budgets. HHS approved the application and budgets; however, the rate in use was not current and the Organization had no active negotiated indirect cost rate agreement (NICRA). Cause: Lapse in monitoring and renewing the negotiated indirect cost rate. Effect or potential effect: Risk of noncompliance with cost principles and potential unallowable indirect cost recoveries if the expired rate differs from an approved current rate. Questioned costs: Undetermined. The variance between the expired rate and an allowable rate was not calculated. Recommendation: Either (1) obtain an updated NICRA from the cognizant agency (HHS) and apply it prospectively and, if required, retroactively. Implement controls to track rate expirations and require documented verification of the current rate before budget submissions and draw requests. Views of responsible officials: Management occurs with the recommendation. See Management’s Corrective Action Plan.

Corrective Action Plan

Corrective Action Plan: Management is in the process of working with HHS to renew the Provisional Rate agreements. The anticipation is that the agreement will be completed by the end of 2025. Anticipated Completion Date: December 31, 2025

Categories

Questioned Costs Allowable Costs / Cost Principles

Programs in Audit

ALN Program Name Expenditures
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $2.07M