Finding Text
Criteria: 2 CFR §200.430 states that incentive compensation is allowable if it is based on cost reduction, efficient performance, suggestion awards or safety awards to the extent that the overall compensation is determined to be reasonable and such costs are paid or accrued according to an agreement entered into in good faith between the recipient and the employees before services were rendered, or according to an established plan followed by the recipient so consistently as to imply, in effect, an agreement to make such payment. Condition: The Organization made incentive compensation payments to employees that lacked the elements required by the Uniform Guidance. Cause: The Organization did not establish written policies and procedures outlining the basis, criteria, and extent of incentive compensation payments before the services were rendered by employees. Effect: In the absence of written policies regarding incentive compensation, there is an increased risk of inconsistent or non-compliant cost allocation practices, which may lead to additional scrutiny, such as questioned costs, audit findings, or even indemnification of the Federal awarding agency for amounts expended on unallowable costs. Questioned Costs: $229,998 Context: The Organization made bonus payments to employees totaling $229,998 during the period under audit. The majority of these incentive compensation payments were allocated across several Federal awards as indirect costs despite the absence of written policies or an established plan that facilitates consistent application of indirect costs to both Federal and non-Federal activities. Recommendation: We recommend that management adopts written policies and procedures for making incentive compensation payments to employees for allowable purposes according to an established plan that contains the required elements set forth in the Uniform Guidance. Furthermore, we recommend that management obtains approval in advance from Federal awarding agencies regarding bonus compensation paid with Federal funds. Views of Responsible Officials: See management’s view and corrective action plan at the end of this report.