Finding 1166954 (2023-005)

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

AI Summary

  • Core Issue: 21 out of 48 tested non-payroll expenses lacked adequate documentation, violating 2 CFR 200.403.
  • Impacted Requirements: Insufficient internal controls over credit card usage led to unallowable costs potentially being charged to federal programs.
  • Recommended Follow-Up: Implement and enforce a policy requiring detailed receipts for credit card charges, with a review process for allowability before submission to federal programs.

Finding Text

2023-005 Allowable Cost Documentation 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: 2 CFR 200.403 requires that costs must be adequately documented. Condition: We selected 48 non-payroll expenses for testing. Of those 48, 21 were found to have insufficient documentation to determine if the cost were allowable or unallowable to the federal program. The 21 expenses found to have insufficient documentation were purchased on a credit card. Cause: The Organization did not maintain sufficient internal controls over credit card usage to ensure detailed receipts were available to support the expense charged to the federal program. Effect: The Organization was not compliance with 2 CFR 200.403 which requires that costs charged to federal programs are adequately documented. Without a policy that requires detailed receipts to be submitted for credit card charges, there is a risk that unallowable costs are charged to the program. Identification as a repeat finding, if applicable: The finding is a repeat of Finding 2022-007 in the prior year. Recommendation: We recommend the Organization implement internal controls that require detailed receipts to be submitted for all credit card charges. The charges listed on the receipts should be reviewed for allowability and approved by the appropriate personnel before charging to the federal program. View of Responsible Officials: The Organization has since implemented a formal credit card policy which requires that detailed receipts be submitted for review and approval for all credit card charges. Questioned Costs: $25,573. This is the total known cost from the 21 transactions identified in our sample to have insufficient documentation.

Corrective Action Plan

Finding 2023-005 – Allowable Cost Documentation In response to the finding, GEM addressed allowable cost documentation by instituting the following: A formal policy was established on 9/30/23, and going forward, GEM will implement additional oversight procedures to ensure the policy is followed and that all requirements are met. GEM has also incorporated the formal credit card policy into the employee handbook, outlining the procedures for submitting receipts on a monthly basis. Anticipated date of completion: This policy has been in effect since September 30, 2023. Responsible party: Jamie 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
  • 1166953 2023-003
    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