Finding Text
Criteria - Federal regulations require that equipment and real property acquired under a federal award be properly documented in accordance with 2 CFR §§200.310–200.313 and applicable program requirements. "Equipment acquired under a federal award must be used for the authorized purposes of the project during the period of performance, or until the property is no longer needed for the project. A HSA may not dispose of, replace, or encumber title to equipment without prior ACF approval (45 CFR section 75.319; 45 CFR section 75.308(c)(1)(xi))." "Property records must be maintained for equipment acquired under a federal award that includes a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), who holds the title, the acquisition date, and cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired the location, use, and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years." Condition and Context - The audit identified gaps in documentation and centralized tracking of equipment and real property acquired under federal awards. Certain historical additions and disposals were not fully documented in accordance with Uniform Guidance, and some current-year asset activity was not captured or reconciled in the property records. Questioned Costs - $14,410 relates to documentation and classification issues identified during the audit. Cause - Property management policies did not fully incorporate current Uniform Guidance requirements, and asset tracking relied on manual processes that were handled across multiple areas and would benefit from more consistent central oversight. Effect - Compliance risk: Noncompliance with property standards increases the risk of disallowed costs, clawbacks, or additional restrictions by the Federal agency. Reporting risk: The Schedule of Expenditures of Federal Awards (SEFA) and related disclosures may be incomplete or inaccurate if property‑related terms and conditions are not followed, affecting low‑risk auditee status evaluations under Subpart F. Recommendation - Update property management policies to mirror requirements in 2 CFR §200.313, §200.311, and §200.310, including explicit steps to (a) verify authorized use, (b) prohibit encumbrances without prior approval, (c) document and seek disposition instructions when no longer needed, and (d) maintain insurance equivalency. Provide targeted staff training and oversight. Views of responsible officials - Management concurs with the finding and views it as an opportunity to modernize property management practices. Corrective actions are underway to strengthen documentation, training, and oversight.