Finding 1240867 (2026-002)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2026
Accepted
2026-10-22
Audit: 415190
Organization: TEXAS AGRICULTURAL LAND TRUST (TX)

AI Summary

  • Core Issue: Payroll charges to federal awards were based on inflated hourly rates, leading to an overstatement of costs by $14,668.
  • Impacted Requirements: Compliance with federal guidelines for allowable costs, specifically accurate record-keeping and internal controls as per §200.430.
  • Recommended Follow-up: Implement new policies to ensure all costs billed to federal awards reflect actual expenses incurred.

Finding Text

Finding #2026-002 – Allowable Costs – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Agriculture, Assistance Listing # 10.932, Regional Conservation Partnership Program, Contract period: 06/14/24 – 12/31/26 Contract number: Supplemental-2983-A-1608, Contract period: 10/31/23 – 07/31/27 Contract number: Supplemental-2757-A-1212, Contract period: 08/29/23 – 03/31/26 Contract number: 917442230013. Passed through Sul Ross State University: Contract period: 04/01/23 – 03/31/26 Contract number: N/A. Criteria: Allowable costs – The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.430 requires that charges to awards for salaries and wages must be based on records that accurately reflect the work performed. These records must 1) be supported by a system of internal control which provides reasonable assurance the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting polies and practices of the agency; and 4) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Condition and context: Of the $1,838,681 expended during the year ended March 31, 2026, approximately $1,729,640 related solely to the purchase of a conservation easement. The remaining expenditures of $109,041 consisted of payroll and related charges. In a sample of three payroll transactions tested, we noted in each case that reimbursement requests were based on hourly rates that exceeded the actual rates of pay of the employees performing the work, resulting in an overstatement of payroll charged to the grantors of $14,668. Cause: Management did not have controls in place to ensure billings accurately reflected only actual costs incurred in accordance with federal award requirements. Effect: Compensation costs charged to the program were based on standard billing rates rather than actual employee compensation costs, resulting in reimbursement requests that exceeded allowable program costs. Known questioned costs: $14,668. Recommendation: Develop policies and procedures to ensure that all costs charged to federal awards are based on actual costs incurred in accordance with federal award requirements. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

Finding #2026-002 – Allowable Costs – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Agriculture, Assistance Listing #10.932, Regional Conservation Partnership Program, Contract period: 06/12/24 – 12/31/26 Contract number: Supplemental-2983-A-1608, Contract period: 10/31/23 – 07/31/27 Contract number: Supplemental-2757-A-1212, Contract period: 08/29/23 – 03/31/26 Contract number: 917442230013, Passed through Sul Ross State University: Contract period: 04/01/25 – 03/31/26 Contract number: N/A. Condition and context: Of the $1,838,681 expended during the year ended March 31, 2026, approximately $1,729,640 related solely to the purchase of a conservation easement. The remaining expenditures of $109,041 consisted of payroll and related charges. In a sample of three payroll transactions tested, we noted in each case that reimbursement requests were based on hourly rates that exceeded the actual rates of pay of the employees performing the work, resulting in an overstatement of payroll charged to the grantors of $14,668. Recommendation: Develop policies and procedures to ensure that all costs charged to federal awards are based on actual costs incurred in accordance with federal award requirements. Planned corrective action: Management will establish procedures to ensure personnel costs charged to federal awards are based on actual allowable employee compensation and supported by appropriate time records. Federal reimbursement requests will be reviewed by the Director of Operations and the Director of Finance prior to submission to ensure that billed costs comply with federal award requirements. Management will also review the questioned costs identified in the audit and coordinate with the applicable grantor regarding any required repayment or adjustment. Responsible officer: Dina McIlhenny, Director of Finance and Brenna Gaik, Director of Operations. Estimated completion date: October 31, 2026.

Categories

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Cash Management Significant Deficiency

Other Findings in this Audit

  • 1240862 2026-001
    Material Weakness Repeat
  • 1240863 2026-001
    Material Weakness Repeat
  • 1240864 2026-001
    Material Weakness Repeat
  • 1240865 2026-002
    Material Weakness Repeat
  • 1240866 2026-001
    Material Weakness Repeat
  • 1240868 2026-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.931 AGRICULTURAL CONSERVATION EASEMENT PROGRAM $6.88M
15.669 COLLABORATIVE LANDSCAPE CONSERVATION $297,231
10.932 REGIONAL CONSERVATION PARTNERSHIP PROGRAM $25,000
10.902 SOIL AND WATER CONSERVATION $20,460