Finding Text
Finding 2025-003: Unsupported Grant Allocation Federal Programs: 19.510 – U.S. refugee Admissions Program – Reception & Placement 93.567 – Refugee and Entrant Assistance Voluntary Agency Program – Matching Grant Compliance Requirement: Allowable Costs/Cost Principles Criteria: The Organization is responsible for establishing and maintaining internal controls over each federal program to ensure that costs charged to the awards are allowable, allocable, reasonable, and supported by adequate documentation in accordance with applicable federal regulations and grant terms. This includes maintaining supporting documentation for amounts claimed for reimbursement. Condition: Of 80 transactions tested for allowable costs, we noted the following exceptions: • Two personnel cost transactions charged to the Reception & Placement Grant differed from the supporting documentation by a net total of $320; and • One utilities transaction charged to the Matching Grant was not supported by documentation that agreed to the amount billed to the grant ($5,239), however, the total utility expenditures organization-wide exceeded the amount claimed. Cause: Management’s review procedures and related internal controls over reimbursement claims were not operating effectively to ensure that amounts billed to federal programs are reconciled to underlying supporting documentation and allocation methodologies prior to submission. Questioned Costs: The results of this noncompliance led to the questioned costs noted in the condition above. Potential Effect: If reimbursement claims are not supported by adequate documentation and reconciled to the underlying records, costs may be misallocated among federal programs or inaccurately charged, which could result in overstated claims, overspending of grant funds, or disallowance of costs by the federal awarding agencies or pass-through entities. Recommendation: We recommend that management establish and document review procedures requiring each reimbursement request to be reconciled to supporting payroll records, invoices, allocation schedules, and other source documentation prior to submission. Evidence of this review should be maintained (for example, via reviewer sign-off or electronic approval) and performed by an individual independent of the preparation of the reimbursement claim. Responsible Official's Response: Management agrees with the finding and the recommendation.