Finding 1206064 (2023-004)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2026-04-07
Audit: 397946
Organization: Voices of Tomorrow (WA)
Auditor: CLARK NUBER PS

AI Summary

  • Core Issue: There is a significant deficiency in internal controls regarding compliance with allowable costs and cost allocation under 2 CFR Part 200.
  • Impacted Requirements: Unallowable costs were charged to federal programs, and the Organization failed to provide adequate documentation for cost allocations.
  • Recommended Follow-Up: Management should enhance review procedures, create formal policies for cost allocation, train staff on federal cost principles, and regularly review allocations for compliance.

Finding Text

Significant deficiency in internal control over compliance with allowable costs and cost allocation under the requirements of 2 CFR Part 200. Federal Agency: Department of Health and Human Services Program Title: Social Services Research and Demonstration Program Assistance Listing Number: 93.647 Project Number: 90XP0459-01-00 Award Period: August 31, 2022 – August 30, 2023 Criteria In accordance with 2 CFR Part 200, costs charged to a federal award must be necessary, reasonable, allowable under the cost principles, allocable, and adequately documented; entertainment costs are specifically unallowable per 2 CFR 200.438, and costs must be allocated consistently between federal awards and other activities, as inconsistent allocation is not permitted under the Uniform Guidance. Condition Unallowable costs were charged to federal programs, and the Organization was unable to substantiate the allocation percentages used for nonpayroll costs during our testing. Cause Unallowable costs were charged because the Organization lacked adequate review procedures to ensure compliance with federal cost principles, and was unable to substantiate allocation percentages used in the allocation of nonpayroll costs during our testing. Effect or Potential Effect The absence of review of charge resulted in $138 of unallowable costs charged to the Federal Program. In addition, our testing of 6 out of 40 selections, adequate supporting documentation was not present to support the allocation of nonpayroll costs. Questioned Costs $4,185 Recommendation We recommend that management develop and implement enhanced review procedures and formal written policies for allocating shared costs to ensure all costs charged to federal awards are allowable under Uniform Guidance, provide training to staff responsible for approving expenditures on federal cost principles, and periodically review allocations for consistency and compliance with federal requirements.

Corrective Action Plan

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management partially disagrees with the characterization of the finding. The Organization had an established cost allocation methodology in place and provided documentation outlining the allocation basis and percentages applied to shared nonpayroll costs. The allocation methodology was reasonable, consistently applied, and based on operational usage. The matter identified during audit testing relates to a difference in interpretation regarding the allocation percentage applied to certain costs. The federal project expected 100% allocation of specific costs directly to the program, whereas the Organization allocated costs proportionally based on a documented cost allocation methodology. The variance was not due to a lack of methodology, but rather a disagreement regarding the appropriate allocation basis under the specific award expectations. While management maintains that the allocation approach was reasonable and consistently applied, we acknowledge the auditor’s interpretation and will revise our documentation and review procedures to ensure alignment with the awarding agency’s expectations going forward. The Organization will accept the adjustment and strengthen formal documentation to eliminate ambiguity in future allocations.Status: Corrective Action Taken Corrective action planned: Management has organized their general ledger to allow for better matching and coding to better identify unallowable costs during the billing process. Additionally, necessary staff were trained on the tracking and approving expenditure on federal cost principles. Reviews will be made on quarterly baises, and all necessary documentation is collected and reviewed. • Develop and formally adopt a written Cost Allocation Plan identifying allocation methodologies. • Implement pre-charge review controls for all federal expenditures. • Establish general ledger coding for unallowable costs. • Provide cost principles training to approving staff. • Conduct periodic allocation consistency reviews. Anticipated completion date: April 2026

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1206061 2023-001
    Material Weakness Repeat
  • 1206062 2023-002
    Material Weakness Repeat
  • 1206063 2023-003
    Material Weakness Repeat
  • 1206065 2023-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.647 SOCIAL SERVICES RESEARCH AND DEMONSTRATION $2.25M