Finding Text
Finding No: 2024-004 Type: Compliance: Unallowable Rent Cost Major Program Affected: Agency: U.S. Department of Agriculture Program Name: American Rescue Plan Technical Assistance Investment Program Assistance Listing No.: 10.234 Award No.: 2023-70417-39226 Compliance Requirement: Allowable Costs / Cost Principles B Condition: During our testing of costs charged to ALN 10.234, we noted rent costs of $14,500 charged to the grant as indirect costs under a related‑party lease arrangement. The leased property was originally the personal residence of members of the management team and was subsequently converted to mixed use, including continued residential use, program activities, storage, and housing available for staff. The auditee did not have a documented indirect cost rate, cost allocation plan, or other formal process or control to determine and support the portion of rent allocable to the federal program. As a result, rent costs were charged to the grant without a reasonable, supportable basis for allocation between personal, 31 non‑program, and program uses. Criteria: Under 2 CFR Part 200, Subpart E – Cost Principles, rental costs are allowable only to the extent that they are reasonable, necessary, and allocable to the federal award and are supported by adequate documentation and an appropriate cost‑allocation methodology for shared or mixed‑use facilities. For related‑party arrangements and facilities used for both personal and business/program purposes, only the portion of rental costs that clearly benefits the federal program and is supported by a reasonable allocation basis may be charged to the award. In the absence of a documented indirect cost rate or cost allocation process, rent charged to the grant that includes personal or non‑program use does not meet the allocability and documentation requirements and is therefore unallowable to the extent it exceeds the portion benefiting the federal program. Questioned Cost: $14,500 Cause: The auditee did not establish a formal indirect cost rate or documented cost allocation methodology for mixed‑use space, and management did not design controls to identify, segregate, and allocate only the portion of related‑party rent that benefits the federal program. Effect or Potential Effect: Because rent was charged to the grant without a documented, supportable allocation between personal, non‑program, and program use, there is a risk that a portion of the rent costs recorded to ALN 10.234 is unallowable or overstated. This may result in misstated federal program expenditures, questioned costs that may need to be refunded to USDA, and increased scrutiny of the auditee’s cost allocation practices and related‑party arrangements in future periods. Repeat Audit Finding: No