Finding 1159690 (2024-003)

Material Weakness Repeat Finding
Requirement
H
Questioned Costs
$1
Year
2024
Accepted
2025-10-01
Audit: 370280
Organization: The Family Conservancy, INC (KS)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: Indirect costs were charged at a 13% rate instead of the allowed 10% for the 2024 grant year.
  • Impacted Requirements: This violates the Uniform Guidance and U.S. GAAP, risking unallowable costs and potential recovery of grant funds.
  • Recommended Follow-Up: Implement stronger controls and procedures for calculating indirect costs to ensure compliance with grant requirements.

Finding Text

Finding 2024-003: Period of Performance – Indirect Costs Federal award agency: U.S. Department of Treasury Pass-through granting agency: Unified Government of Wyandotte County, Kansas and Kansas City, Kansas Program name and ALN: Coronavirus State and Local Fiscal Recovery Funds, 21.027 (COVID-19) Federal award identification number: SLFRP3214 Federal award year: November 17, 2022 to December 31, 2024 Criteria: The Uniform Guidance stipulates that recipients may apply the De Minimis rate at 10% of total direct costs. However, these indirect costs must be charged during the fiscal period (Section 1 states grant period is November 17, 2022 until December 31, 2024) and in accordance with U.S. GAAP per 2 CFR 200.403(e). Condition: During testing, we identified indirect costs were charged at a 13% rate for 2024 grant expenditures due to a catch up from the 2023 year. Cause: Lack of controls and oversight; change in upper level management/turnover during the grant period. Effect or potential effect: Failure to comply with requirements would result in return of unallowable costs and a breach in agreement and may be basis to recover grant funds by grantor. Questioned costs: $34,869 Context: During testing, we identified indirect costs were not charged to the grant at a 10% rate for the 2024 grant year. As such, the Agency's controls were not operating effectively to ensure appropriate calculations of indirect cost rates through the grant period. Repeat finding: No. Recommendation: We recommend that the Agency establish controls and personnel establish and follow procedures to calculate indirect costs charged against grants in accordance with U.S. GAAP. Views of responsible officials: Management agrees with this finding. See corrective action plan.

Corrective Action Plan

Corrective Action Plan Identifying Number: 2024-003 Finding: The Agency did not properly allocate indirect costs during the fiscal period in which the corresponding direct costs were incurred, resulting in an indirect cost rate exceeding the de minimis rate for a portion of the 2024 fiscal period. Corrective Actions Taken or Planned: The Agency concurs with the finding. To correct the cause and ensure compliance with Uniform Guidance requirements for indirect costs, the following actions will be implemented: 1. Establish Written Indirect Cost Procedures – Develop and document procedures to ensure indirect costs are consistently calculated at the approved de minimis rate per the federal grant award on total direct costs during the performance period. 2. Implement Pre-Posting Review – Require a supervisory review of indirect cost calculations before charges are recorded to the general ledger and before grant reimbursements are submitted. We have implemented new procedures to ensure that indirect costs are included in each invoice for reimbursement. 3. Staff Training – Provide training for grants and finance staff on indirect cost requirements, the proper application of the de minimis rate, and reconciliation processes in accordance with 2 CFR 200.414(f). 4. Quarterly Reconciliations – Implement quarterly reconciliations of indirect costs applied to grants to confirm rates are applied correctly and consistently throughout the fiscal year. 5. Continuity Controls – Assign responsibility for indirect cost oversight to both a primary and a backup staff member to ensure consistency during periods of management turnover. Contact Person Responsible for Corrective Action: Fred Timberlake, Vice President of Finance Isha Martin, Controller/Grant Finance Manager Anticipated Completion Date: • New procedures: June 15, 2025 • Written procedures in place: December 31, 2025 • Staff training completed: January 31, 2026 • Supervisory review and reconciliations implemented: Beginning with January 2026 close

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1159688 2024-001
    Material Weakness Repeat
  • 1159689 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.600 Head Start $2.17M
21.027 Covid-19: Coronavirus State and Local Fiscal Recovery Funds $1.28M
10.558 Child and Adult Care Food Program $996,658
93.575 Child Care and Development Block Grant $45,827
93.590 Community-Based Child Abuse Prevention Grants $35,087
16.575 Crime Victim Assistance $21,738