Finding Text
Federal Agency: U.S. Department of Transportation Federal Program Title: Formula Grants for Rural Area and Tribal Transit Program AL Number: 20.509 Federal Award Identification Number and Year: MN-2023-045-00 Pass-Through Agency: Minnesota Department of Transportation Pass-Through Number(s): 1054531 Award Period: 1/1/2024-12/31/2024 Type of Finding: • Material Weakness in Internal Control over Compliance, Material Non-Compliance Criteria or specific requirement: A documented review process ensures that the cost and activity was allowable. Also, supporting evidence should be maintained to ensure budgeted allocations charged to the grant are reviewed after-the-fact to ensure accurate amounts are charged to the grant. Lastly, amounts should be charged to proper grant year. Per CFR Part 200, (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: During our testing of general disbursements, we noted the Organization was missing documentation to support the approval of a general disbursement by someone knowledgeable with the grant. During our testing of payroll disbursements, we noted the Organization did not retain support to show after-the-fact review of budgeted payroll charged to the grant to show the allocation charged to the grant was accurate. During our testing of benefit disbursements, we noted the Organization expended benefits to the incorrect grant year Questioned costs: $3,112 Context: Three of the sixty allowable cost transactions did not have support for review of the costs charged to the grant. Eight of the sixty allowable cost transactions selected for testing did not have adequate support to show the budgeted charge allocated to the grant was reviewed after-the-fact to support the allocation was accurate. One of the sixty allowable cost transactions selected for testing was not charged to the correct grant year. Cause: Management did not have documented approval of allowable costs by someone familiar with the grant. Management did not perform after-the-fact review of budgeted payroll costs allocated to the grant to ensure the costs were accurate and properly allocated. Management did not ensure expenditures are charged to the correct grant year. This was not a statistically valid sample. Effect: Inaccurate amounts of funds could be charged to the grant. Repeat finding: This is a repeat finding. Recommendation: The Organization should ensure proper documentation is retained to support the approval of allowable costs by someone knowledgeable of the grant and its guidelines. The Organization should reconcile the budgeted payroll allocation charged to the grant after-the-fact to actual work performed to ensure the allocation was accurately reflected. The Organization should ensure expenditures are charged to proper grant year. Views of responsible officials and planned corrective actions: There are no disagreements with the audit finding. The Organization will ensure moving forward that proper support is retained for allowable costs charged to the grant and budgeted amounts are reconciled to after-the-fact actual amounts.