Finding Text
Criteria: Under the Uniform Guidance only allowable costs incurred during the approved period of performance may be charged to a federal award. Costs incurred before or after the award period are unallowable unless specifically authorized by the federal agency. Statement of Condition: During our testing over compliance of period of performance, we noted 1 out of 5 expenditures tested was incurred before the award’s period of performance had begun. The invoice date of March 18, 2020 was before the period of performance start date of April 16, 2020, resulting in an unallowable charge to the federal award. Cause of Condition: The entity did not have sufficient controls in place to verify that costs were incurred within the authorized performance period before being charged to the federal award. Contributing factors included inadequate review procedures during invoice processing. Effect of Condition: Charging costs incurred before the period of performance resulted in unallowable costs being charged to the award and noncompliance with federal requirements. Questioned Costs: Questioned costs total $299,880, representing the full amount of expenditure incurred before the period of performance for 1 of 5 expenditures selections. Recommendation: We recommend that management (1) implement or strengthen review procedures to ensure all costs charged to federal awards are incurred within the approved performance period, (2) train personnel responsible for grant accounting on the importance of verifying dates of service, invoice dates, and award period limitations, and (3) consider implementing system-based controls that prevent posting expenditures with dates outside the award period. Identification of Repeat Finding: This finding is a repeat of the finding noted in the audit for December 31, 2019 as finding 2019-005. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.