Finding 1236651 (2025-001)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-09-25
Audit: 412177
Organization: Cultural Vistas, Inc. (DC)

AI Summary

  • Core Issue: CV charged fringe benefit costs to federal awards that exceeded the approved rates in the NICRA.
  • Impacted Requirements: Federal regulations mandate that costs must align with the approved NICRA rates and methodologies.
  • Recommended Follow-Up: Strengthen controls to ensure fringe benefit costs are verified against the approved NICRA before submitting reimbursement requests.

Finding Text

Allowable Costs Federal Agency: U.S. Department of State Federal Program Names: AEECA/ESF PD Programs Professional and Cultural Exchange Programs – Citizen Exchanges Assistance Listing Numbers: 19.900, 19.415 Federal Award Identification Numbers and Years: S-KZ100-24-CA-0069 – 2024 S-ECAGD-21-CA-3030 - 2021 S-ECAGD-24-CA-0508 - 2024 S-ECAGD-23-CA-0064 - 2023 S-ECAGD-24-CA-0555 - 2024 Award Periods: October 1, 2024 through December 31, 2026 March 15, 2021 through January 31, 2026 August 13, 2024 through June 18, 2029 September 15, 2023 through March 31, 2026 August 20, 2024 through March 31, 2027 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: CV's Negotiated Indirect Cost Rate Agreement (NICRA) establishes the approved fringe benefit rate authorized for application to federal awards. Federal regulations require costs charged to federal awards to be consistent with the approved rates and methodologies specified in the NICRA. Management is responsible for establishing and maintaining internal controls to ensure fringe benefit costs charged to federal awards are calculated and applied in accordance with the approved NICRA. Condition: During our testing of indirect costs charged to federal awards, we noted that CV charged actual fringe benefit costs incurred to a federal award in excess of the amount permitted under its approved NICRA. Specifically, fringe benefit costs allocated to the award exceeded the allowable amount calculated using the approved fringe benefit rate. The amount charged in excess of the approved rate resulted in questioned costs below the Uniform Guidance reporting threshold of $25,000 for reporting compliance findings. Questioned costs: None reported, see also Condition above. Context: After identifying an exception in our sample, we evaluated fringe benefit cost charges to the major programs during 2025 to determine the overall impact. Our analysis indicated that the total questioned costs associated with fringe benefit costs charged in excess of the approved fringe benefit rate were below the Uniform Guidance reporting threshold for known questioned costs. Cause: CV did not maintain adequate review controls to verify that fringe benefit costs charged to federal awards were limited to the amount allowable under the approved NICRA. Although actual fringe benefit costs were accumulated and allocated to the program, amounts charged were not reconciled to the approved fringe benefit cost rate limitation prior to submitting reimbursement requests or financial reports. Effect: As a result of the control deficiency, fringe benefit charged to the federal award exceeded the amount allowable under the approved NICRA. Failure to properly monitor fringe benefit cost calculations could result in unallowable costs being charged to federal awards and increases the risk of future noncompliance with federal requirements. Repeat Finding: No Recommendation: We recommend CV strengthen controls over the calculation and review of fringe benefit charged to federal awards. Controls should include a documented review to verify that fringe benefit cost charges are calculated using the currently approved NICRA and that charges to federal awards do not exceed the allowable rate prior to submission of reimbursement requests and federal financial reports. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

AEECA/ESF PD Programs -Assistance Listing No. 19.900 Professional and Cultural Exchange Programs - Citizen Exchanges - Assistance Listing Number 19.415 Recommendation: Cultural Vistas, Inc. should strengthen controls over the calculation and review of fringe benefit charged to federal awards. Controls should include a documented review to verify that fringe benefit cost charges are calculated using the currently approved NICRA and that charges to federal awards do not exceed the allowable rate prior to submission of reimbursement requests and federal financial reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has not applied for the fringe benefit negotiated indirect rate as offiscal year 2026. For any future fringe benefit NICRA, a Finance team member will review the charges to the federal award against the allowable rate quarterly to ensure the correct rate was applied. If the amount exceeds the allowable rate, an adjustment will be made on a quarterly basis to reduce the fringe benefit expense according to the allowable rate. Name(s) of the contact person(s) responsible for corrective action: Megan Bah Planned completion date for corrective action plan: July 14, 2026

Categories

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties Cash Management Significant Deficiency

Other Findings in this Audit

  • 1236647 2025-001
    Material Weakness Repeat
  • 1236648 2025-001
    Material Weakness Repeat
  • 1236649 2025-001
    Material Weakness Repeat
  • 1236650 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
19.402 PROFESSIONAL AND CULTURAL EXCHANGE PROGRAMS - INTERNATIONAL VISITOR LEADERSHIP PROGRAM $2.62M
19.900 AEECA/ESF PD PROGRAMS $1.15M
19.415 PROFESSIONAL AND CULTURAL EXCHANGE PROGRAMS - CITIZEN EXCHANGES $449,597
19.415 NON-DISCRIMINATION ON THE BASIS OF SEX IN EDUCATION PROGRAMS AND ACTIVITIES RECEIVING FEDERAL FINANCIAL ASSISTANCE $226,736
19.040 PUBLIC DIPLOMACY PROGRAMS $15,700