Finding 1236114 (2025-002)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-09-23
Audit: 411744
Organization: LEAGUE OF HUMAN DIGNITY INC (NE)

AI Summary

  • Core Issue: The League did not comply with the Uniform Audit Guidance Subpart E-Cost Principles.
  • Impacted Requirements: Costs must be consistently charged as either direct or indirect, with adequate documentation to support all charges.
  • Recommended Follow-Up: The League should implement the Corrective Action Plan to align with the required cost principles.

Finding Text

Reference Number Material Weakness 2025-002 Did not follow Uniform Audit Guidance Subpart E-Cost Principles. Criteria or Specific Requirement: Uniform Audit Guidance Subpart E-Cost Principles. Condition: The League did not follow Uniform Audit Guidance Subpart E-Cost Principles. Effect: The League is not in compliance with Uniform Audit Guidance Subpart E-Cost Principles. Cause: When applying the de minimis rate, costs must be consistently charged as either direct or indirect costs and may not be double charged or inconsistently charged as both. Costs must be consistent with these cost principles and support the accumulation of costs as required by these cost principles, including maintaining adequate documentation to support costs charged to the Federal award. Likely Questioned Costs: De Minimis Questioned Costs: $879,207 Inconsistent with Cost Principles and Inadequate Documentation Questioned Costs: $495,730 Recommendation: The League should follow the Uniform Audit Guidance Subpart E-Cost Principles. Response: See Corrective Action Plan.

Corrective Action Plan

The corrective action plan for the internal control material weakness, noncompliance with Uniform Audit Guidance Subpart E-Cost Principles (2025-002), is summarized as follows: Corrective Action Planned: Management respectfully disagrees with the finding that indirect costs were double charged. The Organization uses the Direct Allocation Method described in Appendix IV to 2 CPR Part 200. Under this method, joint costs are allocated directly to benefiting programs and activities using allocation bases designed to reflect the relative benefits received. General administrative and general expenses are treated as indirect costs. The Organization also elected to use the de minimis indirect cost rate permitted by 2 CPR§ 200.414(f). Management believes the costs allocated directly to the federal award and the costs recovered through application of the de minimis rate represent separate cost categories and that no individual cost was charged to the award both directly and indirectly. Management's allocation methodology and resulting charges were also reviewed and approved by the grantor, and management relied on that approval in determining that its treatment was acceptable. Although management disagrees with the finding, the Organization will review and enhance its written cost-allocation procedures to more clearly identify: • Costs charged directly to each federal award; • Joint costs allocated under the Direct Allocation Method; • General administrative costs treated as indirect costs; and • Controls designed to ensure that costs charged directly are not also recovered through another allocation or reimbursement method. Management will also retain documentation supporting the allocation bases used, the calculation and application of the de minimis rate, and relevant grantor approvals and communications. Anticipated Completion Date: Responsible: Management and Board of Directors.

Categories

Allowable Costs / Cost Principles Material Weakness

Other Findings in this Audit

  • 1236113 2025-001
    Material Weakness Repeat
  • 1236115 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.778 GRANTS TO STATES FOR MEDICAID $8.00M
93.432 ACL CENTERS FOR INDEPENDENT LIVING $1.04M
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $116,468
93.369 ACL INDEPENDENT LIVING STATE GRANTS $70,359
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $35,407