Finding 1166953 (2023-003)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2023
Accepted
2025-12-29

AI Summary

  • Core Issue: Indirect costs were allocated based on budgeted figures instead of actual costs, lacking necessary reviews and approvals.
  • Impacted Requirements: Non-compliance with 2 CFR 200.414, which mandates accurate allocation of indirect costs to ensure financial transparency.
  • Recommended Follow-Up: Establish clear policies and procedures for monthly review and approval of allowable indirect costs, ensuring they are reported separately in the accounting ledger.

Finding Text

2023-003 Indirect Cost Allocations - Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Program: Research and Development Cluster (ALN 47.041-Engineering, Award 1940055, Award Period 9/1/19 – 3/31/25 and ALN 47.084-Technology, Innovation and Partnerships, Award 1940055, Award Period 9/19/22 – 3/31/25) Federal Agency: National Science Foundation Criteria: Program costs for allocation of indirect costs should be based on percentage of total costs at year end and allocated based on specific allocations of costs incurred and approved in a timely manner as required by 2 CFR 200.414. Condition: Our testing noted that program charges included nine monthly journal entries to allocate indirect costs based on budgeted calculations and one year-end entry to adjust the calculation based on actual results. The entries did not have the necessary review and approvals to ensure allowability of the costs to activities. Cause: The Organization lacks written policies, approval procedures and documentation to allocate indirect costs to the program. Effect: The Organization is not compliant with 2 CFR 2 CFR 200.414 which requires accurate, and complete disclosure of financial results including the allocation of approved and identified actual indirect costs incurred to the program in accordance with 2 CFR 200.414. Without a policy of reviewing and approving indirect costs on a regular basis, there is a risk that unallowable costs are allocated to the program. Identification as a repeat finding, if applicable: The finding is a repeat of Finding 2022-005 in the prior year. Recommendation: We recommend the Organization establish policy and procedures to identify and approve allowable indirect costs chargeable to the program on a monthly basis and report this allocation in the accounting ledger separately from the general expenses of the company. View of Responsible Officials: The Organization has since implemented controls and procedures to allocate indirect costs to program costs based on incurred costs. Monthly allocations are approved by the program administrator and separately reported in the general ledger. Questioned Costs: $202,309 – This is the amount of indirect costs charged to the program.

Corrective Action Plan

Finding 2023-003 – Indirect Cost Allocations In response to the finding, GEM will improve program costs allocation documentation by instituting the following controls and procedures: GEM allocated indirect costs to the NSF program based on actual expenses incurred and monthly allocations approved by the program administrator. These indirect costs are recorded separately in the accounting system. Formal written procedures are now in place, and we will maintain active oversight to ensure full adherence to all established policies. Anticipated date of completion: Monthly journal entry is set up with calculations for determining the dollar amount. The date of completion was October 2022 and have been updated since then. Responsible party: Jamie D. Hicks, Senior Accounting Manager

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1166949 2023-002
    Material Weakness Repeat
  • 1166950 2023-003
    Material Weakness Repeat
  • 1166951 2023-004
    Material Weakness Repeat
  • 1166952 2023-005
    Material Weakness Repeat
  • 1166954 2023-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
47.041 ENGINEERING $687,414
47.084 NSF TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $616,264
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $470,500