Finding 1239602 (2025-007)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: AEA failed to support their cost allocation method for 15 out of 60 cash disbursements, violating 2 CFR 200.405.
  • Impacted Requirements: The lack of proper documentation means AEA is not compliant with federal cost allocation guidelines.
  • Recommended Follow-Up: AEA should review and update their allocation methodology to ensure compliance and prevent repeat findings.

Finding Text

Criteria: In accordance with 2 CFR 200.405, costs must be allocated to the projects based on the proportional benefit. If this cannot be determined, costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Condition: For the year ended December 31, 2025, AEA did not maintain support for their allocation methodology for 15 out of 60 cash disbursement items selected. Cause: The expense allocations may not be appropriate. Effect: AEA is not in compliance with 2 CFR 200.405. Questioned Costs: Undeterminable. Context: A random sampling of the federal expenditures. Repeat Finding: This finding was not corrected. See finding item 2024-006 in the prior year findings. Recommendation: We recommend that AEA review and reestablish their allocation methodology for allocated costs. View of Responsible Officials: Refer to management’s corrective action plan.

Corrective Action Plan

Responsible contact(s): Agnes, Controller, for methodology and review; Laura, CFO, for approval; Program Managers for benefit evidence. Participating staff: AP Staff Accountant after onboarding; Trina for interim AP documentation; Steve for claim reconciliation; Trina for allocation-workpaper checks. During 2026, management has been working on a documented, consistently applied allocation methodology. 1. Approve a written allocation plan. Agnes will finalize shared-cost pool, the activities benefiting, the allocation driver, calculation, source records, update frequency, and approval responsibility. Program Managers will substantiate benefit, and Laura will approve the plan. Personnel allocations will follow actual activity under finding 2025-006, not budget availability. 2. Use supportable drivers. Potential drivers include occupied square footage for space-related costs, assigned users for licenses, and documented usage for shared services. These are proposed examples, not AEA's established methodology. The selected basis must fit the benefit received, include all benefiting Federal and non-Federal activities, and be documented. Available grant balances will not determine the allocation. 3. Support each calculation. Trina, and subsequently the AP Staff Accountant, will retain the invoice and approved allocation worksheet showing the full cost, driver quantities, proportions, allocated amounts, and fund/category coding. Agnes and later Trina will check calculations and reconciliation to the source amount; Laura and subsequently Agnes will approve. Steve will reconcile the approved allocation to billed costs and retain supporting references. 4. Prevent inconsistent or duplicate recovery. Agnes will review changes in space, staffing, users, or program activity and update the basis when warranted, with formal quarterly review. Directly charged costs will be excluded from any indirect recovery of the same cost. General administrative pools will follow the applicable indirect-cost method and award limitations; costs will not be shifted to another award to overcome a funding deficiency. 5. Resolve the historical population. Agnes and Program Managers will review 2026 allocations through final implementation. Any reconstructed basis will use credible period-specific evidence, not unsupported hindsight percentages. Laura will approve supported corrections and direct funder resolution where needed. Training will cover invoice preparation, benefit documentation, and approval. Anticipated completion Documented review of all new shared-cost allocations: October 15, 2026. Written allocation plan and training: October 30, 2026. Review of cited items and similar allocations: November 30, 2026. Anticipated completion: February 15, 2027.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1239565 2025-006
    Material Weakness Repeat
  • 1239566 2025-007
    Material Weakness Repeat
  • 1239567 2025-008
    Material Weakness Repeat
  • 1239568 2025-009
    Material Weakness Repeat
  • 1239569 2025-006
    Material Weakness Repeat
  • 1239570 2025-007
    Material Weakness Repeat
  • 1239571 2025-008
    Material Weakness Repeat
  • 1239572 2025-009
    Material Weakness Repeat
  • 1239573 2025-006
    Material Weakness Repeat
  • 1239574 2025-007
    Material Weakness Repeat
  • 1239575 2025-008
    Material Weakness Repeat
  • 1239576 2025-009
    Material Weakness Repeat
  • 1239577 2025-006
    Material Weakness Repeat
  • 1239578 2025-007
    Material Weakness Repeat
  • 1239579 2025-008
    Material Weakness Repeat
  • 1239580 2025-009
    Material Weakness Repeat
  • 1239581 2025-006
    Material Weakness Repeat
  • 1239582 2025-007
    Material Weakness Repeat
  • 1239583 2025-008
    Material Weakness Repeat
  • 1239584 2025-009
    Material Weakness Repeat
  • 1239585 2025-006
    Material Weakness Repeat
  • 1239586 2025-007
    Material Weakness Repeat
  • 1239587 2025-008
    Material Weakness Repeat
  • 1239588 2025-009
    Material Weakness Repeat
  • 1239589 2025-006
    Material Weakness Repeat
  • 1239590 2025-007
    Material Weakness Repeat
  • 1239591 2025-008
    Material Weakness Repeat
  • 1239592 2025-009
    Material Weakness Repeat
  • 1239593 2025-006
    Material Weakness Repeat
  • 1239594 2025-007
    Material Weakness Repeat
  • 1239595 2025-008
    Material Weakness Repeat
  • 1239596 2025-009
    Material Weakness Repeat
  • 1239597 2025-006
    Material Weakness Repeat
  • 1239598 2025-007
    Material Weakness Repeat
  • 1239599 2025-008
    Material Weakness Repeat
  • 1239600 2025-009
    Material Weakness Repeat
  • 1239601 2025-006
    Material Weakness Repeat
  • 1239603 2025-008
    Material Weakness Repeat
  • 1239604 2025-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $766,832
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $381,396