Finding 1158151 (2024-002)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 370075
Organization: Think Regeneration (IL)

AI Summary

  • Core Issue: The Organization lacks evidence of reviewing expenses charged to the grant, violating compliance requirements.
  • Impacted Requirements: Non-compliance with 2 CFR Section 200.302 regarding allowable costs and internal control procedures.
  • Recommended Follow-Up: Implement a written procurement policy to ensure adherence to 2 CFR Section 200.302 and improve expense review processes.

Finding Text

Significant Deficiency 2024-002 Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments – Allowable Cost and Cost Principles Information on Federal Program: U.S. Department of Agriculture (Federal Assistance Listing Number 10.182). Criteria: CFR Section 200.302 stipulates that a non-Federal entity must use its own written procedures for determining the allowability of costs in accordance with Subpart E-Cost Principles of this part and the terms and conditions of the Federal award. Statement of Condition: During our discussions with management, we noted that the Organization does not have evidence of review of expenses charged to the grant. Statement of Cause: The Organization did not review compliance requirements related to allowable cost and cost principles outlined in 2 CFR Section 200.302. Statement of Effect: The Organization is not in compliance with 2 CFR Section 200.302. The Organization does not have evidence of review and is therefore not performing required procedures that would be standard for all purchases charged to the program. Questioned Costs: None. Perspective Information: As part of the required allowable cost testing, inquiries are made of the Organization’s management as to any internal control policies that the Organization has. Recommendation: We recommend that the Organization review the requirements of 2 CFR Section 200.302 to follow their internal control policies. Views of responsible officials and planned corrective actions: Think Regeneration, NFP will develop and implement a written procurement policy in accordance with CFR Section 200.302. We will have this in place as soon as possible.

Corrective Action Plan

The organization recognizes the importance of having written policies and procedures to ensure costs are allowed and reasonable for the federal program. To address this finding, the agency has implemented the following corrective actions: • Review requirements of 2 CFR Section 200.302 as it relates to internal controls and financial management • Create documented policies and procedures that details how the grantee will review and approve invoices, cost allocation, efforts of personnel, fringe benefits and indirect charges for allowability, adherence to cost principles, accuracy, and completeness • Create documented policies and procedures that details how the grantee will review and approve invoices, cost allocations, efforts of personnel, fringe benefits and indirect charges to ensure they were incurred during the period of performance

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.182 Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments $1.26M