Finding 1161701 (2024-002)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2024
Accepted
2025-10-31

AI Summary

  • Core Issue: Some expenses were charged to the grant outside the approved performance period, violating federal guidelines.
  • Impacted Requirements: Costs must be allowable, allocable, and incurred within the grant's specified performance period to ensure compliance.
  • Recommended Follow-Up: Implement a formal review process to validate transaction dates and provide training for staff on grant accounting.

Finding Text

Criteria and Context: Per the Office of Management and Budget (OMB) Uniform Guidance, specifically 2 CFR Part 200, costs charged to federal awards must be allowable, allocable, and incurred within the period of performance specified by the grant agreement. Expenses incurred outside the designated performance period are not eligible for reimbursement under the award and may result in noncompliance. Effective internal control over compliance requires that expenditures be reviewed to ensure they are properly timed and aligned with the terms and conditions of the federal award. Condition: During our audit procedures over allowable costs, we identified two instances from a sample of forty in which expenses were charged to the grant outside of the approved period of performance. Cause and Effect: The exceptions noted were related to invoices that spanned a period that began within the period of performance but had a portion that extended beyond. The transaction timing was insufficiently reviewed during the expense allocation process, and adequate controls were not in place to verify that all costs charged to the grant were incurred within the period of performance. Questioned Costs: None reported Identified as a Repeat Finding: No Recommendation: Management should strengthen controls around recording and charging grant expenses by implementing a formal review process to ensure all costs are incurred within the designated period of performance. This process should include validation of transaction dates prior to posting and periodic training for staff responsible for grant accounting. Management Response and Remediation: Management acknowledges the exceptions and has taken steps to improve the review of grant-related expenditures.

Corrective Action Plan

Audit Finding 2024-002 Reference: Expenses charged to federal awards outside the designated period of performance. (2 out of 40 sampled) ________________________________________1. Issue Summary The audit identified two instances where expenses were charged to a federal grant outside the approved period of performance. These expenses were tied to invoices that began within the period of performance and a portion extended beyond the performance period. The root cause was insufficient review of transaction timing and lack of controls to ensure compliance with Uniform Guidance requirements. ________________________________________ 2. Root Cause Analysis Lack of a formalized review process for validating transaction that span extended period dates that may extend past grant period of performance. ________________________________________ 3. Corrective Actions A. Implement a Formal Expense Review Protocol • Develop and document a standard operating procedure (SOP) for reviewing all grant-related expenses. • Require validation of invoice service dates and delivery dates before posting to federal awards • Include a checklist for SPF accountants to confirm alignment with the period of performance. B. Staff Training and Awareness • Conduct mandatory training sessions for all staff involved in grant accounting and expense processing. • Include guidance on: o Allowable costs under 2 CFR Part 200 o Period of performance compliance o Documentation standards ________________________________________ 4. Responsible Parties • Finance Director: Oversight and implementation of corrective actions • Sponsored Projects Finance Team: Execution of SOP and transaction reviews ________________________________________ 5. Timeline Action Item Target Completion Date Policy Development Already implemented Staff Training Completed initial training, additional will be ongoing

Categories

Allowable Costs / Cost Principles Period of Performance

Other Findings in this Audit

  • 1161696 2024-001
    Material Weakness Repeat
  • 1161697 2024-001
    Material Weakness Repeat
  • 1161698 2024-001
    Material Weakness Repeat
  • 1161699 2024-002
    Material Weakness Repeat
  • 1161700 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
98.001 USAID FOREIGN ASSISTANCE FOR PROGRAMS OVERSEAS $12.24M
19.345 INTERNATIONAL PROGRAMS TO SUPPORT DEMOCRACY, HUMAN RIGHTS AND LABOR $281,621
19.510 U.S. REFUGEE ADMISSIONS PROGRAM $83,133
19.121 CONFLICT AND STABILIZATION OPERATIONS $2,931