Finding 1205504 (2025-005)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-03-31
Audit: 397187
Auditor: REDW LLC

AI Summary

  • Core Issue: Indirect costs were charged twice to the federal award due to improper budget preparation.
  • Impacted Requirements: This practice violates 2 CFR Part 200, leading to noncompliance with federal cost principles.
  • Recommended Follow-Up: Strengthen controls by reviewing budgets, requiring supervisory checks, training staff, and assessing the need for corrections.

Finding Text

Funding agency: U.S. Department of Transportation, Federal Highway Administration. Title: Highway Planning and Construction. CFDA number: 20.205. Award year and number: 2025 – PO-73000-00034057. Criteria: Under 2 CFR Part 200, Subpart E, costs charged to a federal award must be allowable, reasonable, allocable, and consistently treated. Indirect costs may not be charged both directly and through application of an approved indirect cost rate, as this results in duplicate reimbursement of the same costs. Condition: OCWCOG submitted a grant budget that included indirect-cost-type expenditures within direct expense line items as well as within the indirect cost rate submission calculation, which resulted in indirect costs being charged twice to the federal award. Questioned Costs: None reported. The known likely questioned costs are below $25,000. Cause: As a result of turnover within the planning department, management did not have adequate controls over the preparation and review of grant budgets and reimbursement calculations to ensure indirect costs included in grant budgets were excluded from the indirect cost rate calculation. Effect: The federal award was charged unallowable duplicate indirect costs. Although the amount identified was less than the Uniform Guidance questioned costs reporting threshold of $25,000, the practice resulted in noncompliance with federal cost principles and increases the risk that federal awards may be overcharged. Auditor’s Recommendations: We recommend the governmental entity strengthen internal controls over grant budgeting and claims for reimbursement by: 1. Reviewing grant budgets to ensure indirect costs are not embedded in direct cost line items when an indirect cost rate will be applied; 2. Requiring supervisory review of the indirect cost base and related calculations prior to submission; 3. Providing training to personnel responsible for federal grant accounting on allowable cost requirements under 2 CFR Part 200; and 4. Evaluating whether any adjustment or correction to the grantor is necessary for the duplicate indirect costs identified. Management’s Response: Management is revising procedures to ensure their methodology of applying indirect costs is consistent throughout all grants to ensure that only allowable indirect expenses are charged. These updates are being made in the current budget cycle.

Corrective Action Plan

We have revised our process and operating procedure to apply indirect cost methods consistently across all federal grants. We have already corrected the error in FY 2026.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1205500 2025-004
    Material Weakness Repeat
  • 1205501 2025-004
    Material Weakness Repeat
  • 1205502 2025-004
    Material Weakness Repeat
  • 1205503 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $756,219
20.205 HIGHWAY PLANNING AND CONSTRUCTION $515,569
66.818 BROWNFIELDS MULTIPURPOSE, ASSESSMENT, REVOLVING LOAN FUND, AND CLEANUP COOPERATIVE AGREEMENTS $285,768
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $270,219
93.778 GRANTS TO STATES FOR MEDICAID $201,481
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $200,981
94.011 AMERICORPS SENIORS FOSTER GRANDPARENT PROGRAM (FGP) 94.011 $139,970
94.002 AMERICORPS SENIORS RETIRED AND SENIOR VOLUNTEER PROGRAM (RSVP) 94.002 $135,157
94.016 AMERICORPS SENIORS SENIOR COMPANION PROGRAM (SCP) 94.016 $113,334
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $89,944
10.767 INTERMEDIARY RELENDING PROGRAM $86,300
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $67,936
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $31,643
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $29,347
93.324 STATE HEALTH INSURANCE ASSISTANCE PROGRAM $23,959
93.048 SPECIAL PROGRAMS FOR THE AGING, TITLE IV, AND TITLE II, DISCRETIONARY PROJECTS $19,500
93.071 MEDICARE ENROLLMENT ASSISTANCE PROGRAM $13,050
93.041 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 3, PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND EXPLOITATION $2,995