Finding 1160858 (2024-002)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
$1
Year
2024
Accepted
2025-10-16

AI Summary

  • Core Issue: The Cooperative charged $1,779,669 for unallowable costs related to electrical infrastructure under the Tribal Broadband Grant Program.
  • Impacted Requirements: Costs must be for allowable activities; proper segregation of billing for different activities is essential.
  • Recommended Follow-Up: Train all project management personnel on federal grant compliance and ensure vendors separate billings for allowable and unallowable activities.

Finding Text

Identification of the federal program: 11.029 – Tribal Broadband Grant Program Criteria: Processes and procedures should be in place to ensure costs charged to the grant are only for activities that are allowed. Condition: The Cooperative identified costs that had been submitted and reimbursed under the program that were for electrical infrastructure development which is not an allowable activity. Cause: Costs charged on the vendor invoice were not separated between allowable activity, broadband infrastructure development, and unallowable activity, electrical infrastructure development. Effect: The Cooperative received $1,779,669 of reimbursement for unallowable activities. The granting agency, the National Telecommunications and Information Administration, has been notified and a credit for the amount has been applied against the Cooperative’s May 2025 drawdown to correct the error. Known Questioned Costs: $1,779,669 Recommendations: When projects include both allowable and unallowable activities, the Cooperative should instruct the vendor to segregate accounting related to the different activities in their billings. Cooperative personnel and consultants involved in project management, especially those involved in approving expenditures, should receive training on Uniform Guidance requirements. Views of Responsible Officials: The Cooperative agrees with the finding above and has already taken corrective action. All project expenditures for the term of the grant have been reviewed for any additional unallowable charges. Training meetings have been held with contractors and subcontractors to ensure clear distinction and segregated accounting between grant and non-grant projects in project billings. The Cooperative will ensure that all personnel involved in grant administration, including project managers and finance staff, are required to attend training on federal grant compliance.

Corrective Action Plan

Cause: Costs charged on the vendor invoice were not separated between allowable activity, broadband infrastructure development, and unallowable activity, electrical infrastructure development. Corrective Action Plan: “The corrective action has already been taken prior to audit completion. The costs related to unallowable activities have been reimbursed to the grant in the form of an offset against May 2025 draw to correct the error. All project expenditures incurred to date were reviewed to confirm there were no additional unallowable charges. Training was provided to contractors and subcontractors involved with the project to ensure a thorough understanding of the importance of maintaining separate accounting records for grant and non-grant projects. Furthermore, all personnel involved in grant administration, including project managers and finance staff, are required to attend training on federal grant compliance. Going forward, project and support teams will perform a more comprehensive review of project invoices and billing details as well as monitor project’s spend variances more closely to ensure grant compliance.”

Categories

Questioned Costs Cash Management Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1160857 2024-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.029 Tribal Broadband Connectivity Program $16.59M