Finding 1203083 (2025-002)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396301
Organization: The Land Institute (KS)

AI Summary

  • Core Issue: The Institute lacks detailed time and activity records to support salary and fringe benefit expenses charged to federal grants.
  • Impacted Requirements: Federal regulations require accurate records and internal controls for salary charges; budget estimates alone are insufficient.
  • Recommended Follow-Up: Implement a compliant time and activity tracking method to ensure proper documentation for federal awards.

Finding Text

Information on the federal program: Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods Criteria or specific requirement: Allowable Costs/Cost Principles Federal regulations state that “charges to federal awards for salaries and wages, must be based on records that accurately reflect the work performed.” The regulations also state that “the records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and property allocated” and “budget estimates alone do not qualify as support for charges to federal awards” (2 CFR 200.430(i)). Condition: During our test work over the Research and Development cluster, we noted the Institute did not have time and activity records with sufficient detail per federal regulations to support its salary and fringe benefit expenses. Cause: Lack of understanding of the requirements of the time and activity reports. Effect of Potential Effect: Based on testing completed, the Institute did not have sufficient procedures to record and verify employees time and activity throughout fiscal year 2025. Questioned Costs: Total questioned costs are $556,632. This includes all salaries and benefits charged to the cluster which lacked documentation to support the charge and allocation to the grant. Assistance Listing Number & Questioned Costs 10.001 - $10,000 10.216 - $5,333 10.303 - $45,801 10.307 - $7,167 10.310 - $457,524 10.326 - $30,807 Context: We selected a sample of 25 salary and benefit charges to the Research and Development cluster. Within our sample we noted that that none of the selections had proper documentation to support the charge and allocation to the grant (e.g. , daily time and activity records, effort verification reports, etc.). These 25 selections had a value of $24,352. Per discussions with management and further review, the amounts charged to the grant were based on the approved budget for the position and the internal allocation performed each payroll period. Salaries and benefits charged to the grant in the audit period totaled $556,632 and represented 59% of the total grant expenditures for the period. The sample was not intended to be, and was not, a statistically valid sample. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend management utilize a time and activity tracking method that will meet the requirements of federal regulations. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the stated finding and has implemented a corrective action plan.

Corrective Action Plan

Finding Reference 2025-002 Personnel Responsible for Corrective Action: Drafting of policy, procedures, and forms will be completed by Westen Gehring (Grants Specialist) and Laura Froese (Accounting Manager), with input and final approval provided by Tracie Thomas (Chief Operating Officer) Anticipated Completion Date: The Effort Verification Policy and related procedures will be finalized by July 1, 2026, for implementation in Fiscal Year 2027. Retroactive effort certification for the period July 1, 2025 through March 31, 2026 will be completed by June 30, 2026. Monthly implementation tests of the new policies and procedures will begin with the April 2026 reporting period. Views of Responsible Officials and Planned Corrective Action: Concur. Corrective Actions Planned: The Land Institute will implement a formal effort reporting system effective July 1, 2026 (Fiscal Year 2027), including finalized policies, procedures, and standardized effort certification forms designed to ensure compliance with 2 CFR 200.430 As part of the transition to this system, retroactive effort certifications will be completed for Fiscal Year 2026 for the period of July 1, 2025 through March 31, 2026 to support payroll costs previously charged to federal awards. The months of April through June 2026 will be utilized as an implementation and testing period to establish and refine the monthly effort certification process. During this time, The Land Institute will complete effort certifications on a monthly basis, reflecting an after-the-fact determination of actual work performed across all institutional activities, and integrate the certification process into month-end close procedures. This phased implementation approach will allow management to validate processes, ensure accuracy and completeness of certifications, and make any necessary adjustments prior to full implementation in Fiscal Year 2027. Training will be provided to all applicable staff to ensure understanding of effort reporting requirements and compliance expectations. Finance and Grants personnel will monitor compliance and timeliness of certifications, and ongoing monitoring controls will be implemented to ensure continued compliance.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1203070 2025-002
    Material Weakness Repeat
  • 1203071 2025-002
    Material Weakness Repeat
  • 1203072 2025-002
    Material Weakness Repeat
  • 1203073 2025-002
    Material Weakness Repeat
  • 1203074 2025-002
    Material Weakness Repeat
  • 1203075 2025-002
    Material Weakness Repeat
  • 1203076 2025-002
    Material Weakness Repeat
  • 1203077 2025-002
    Material Weakness Repeat
  • 1203078 2025-002
    Material Weakness Repeat
  • 1203079 2025-002
    Material Weakness Repeat
  • 1203080 2025-002
    Material Weakness Repeat
  • 1203081 2025-002
    Material Weakness Repeat
  • 1203082 2025-002
    Material Weakness Repeat
  • 1203084 2025-003
    Material Weakness Repeat
  • 1203085 2025-003
    Material Weakness Repeat
  • 1203086 2025-003
    Material Weakness Repeat
  • 1203087 2025-003
    Material Weakness Repeat
  • 1203088 2025-003
    Material Weakness Repeat
  • 1203089 2025-003
    Material Weakness Repeat
  • 1203090 2025-003
    Material Weakness Repeat
  • 1203091 2025-003
    Material Weakness Repeat
  • 1203092 2025-003
    Material Weakness Repeat
  • 1203093 2025-003
    Material Weakness Repeat
  • 1203094 2025-003
    Material Weakness Repeat
  • 1203095 2025-003
    Material Weakness Repeat
  • 1203096 2025-003
    Material Weakness Repeat
  • 1203097 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.219 BIOTECHNOLOGY RISK ASSESSMENT RESEARCH $230,630
47.074 BIOLOGICAL SCIENCES $211,491
10.303 INTEGRATED PROGRAMS $50,393
10.326 CAPACITY BUILDING FOR NON-LAND GRANT COLLEGES OF AGRICULTURE (NLGCA) $37,558
10.215 SUSTAINABLE AGRICULTURE RESEARCH AND EDUCATION $20,672
10.216 1890 INSTITUTION CAPACITY BUILDING GRANTS $12,035
10.001 AGRICULTURAL RESEARCH BASIC AND APPLIED RESEARCH $11,000
10.307 ORGANIC AGRICULTURE RESEARCH AND EXTENSION INITIATIVE $7,884
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $4,025