Finding 1241719 (2025-004)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-11-06
Audit: 415738
Organization: City of Atlanta (GA)

AI Summary

  • Core Issue: The City failed to submit an indirect cost rate proposal to the cognizant agency, violating federal requirements for grants over $35 million.
  • Impacted Requirements: Compliance with Title 2 U.S. Code of Federal Regulations Part 200, specifically regarding indirect cost rates and internal controls.
  • Recommended Follow-Up: Enhance internal controls to ensure future compliance with indirect cost rate requirements and implement a process for applying the de minimis rate to all federal awards.

Finding Text

Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires recipients of federal funding grants who charge indirect costs to a grant to either use the de minimis cost rate of 10% or have a negotiated indirect cost rate approved by a cognizant agency. Furthermore, recipients of federal funding in excess of $35 million in direct federal funding are required to develop an indirect cost rate proposal and submit that proposal to its cognizant agency for indirect costs when they elect to use a rate that exceeds the 10% de minimis rate. Condition: Internal controls should be in place to ensure the City is in compliance with all requirements of the federal award program. The City did not submit their indirect cost rate proposal to their cognizant agency. Context/Cause: The City did not have adequate internal controls to ensure compliance with indirect cost rate requirements. The City received more than $35 million in direct federal funding and did not submit their required indirect cost rate proposal for approval to a cognizant agency after electing not to use the 10% de minimis rate. The rate charged to the CSLFRF program for the current fiscal year was greater than the 10 percent de minimis rate, but the total indirect costs charged under that rate during the current fiscal year did not exceed 10% of the total federal award. Effects: Controls were not in place over the process of allowable indirect costs. Questioned Costs: None Recommendation: We recommend the City enhance internal controls to ensure compliance with indirect cost rate requirements. Auditee’s Response: Management will establish a process to apply the de minimis rate to all relevant federal awards going forward.

Corrective Action Plan

In response to this finding, management will take the following actions. 1. Adoption of the De Minimis Rate: The City will apply the 15% de minimis indirect cost rate, as permitted under Uniform Guidance, to applicable federal awards where a federally negotiated indirect cost rate agreement is not in place. This approach will provide consistency in the recovery of indirect costs and ensure compliance with federal requirements. 2. Formalize Procedures: The Controller's Office will develop and document procedures governing the application of indirect cost rates, including guidance on when the de minimis rate may be used, calculation methodologies, required documentation, and approval requirements. 3. Training: Training will be provided to grants management, accounting, and program staff responsible for grant budgeting, financial reporting, and reimbursement requests to ensure a clear understanding of indirect cost rate requirements and the application of the minimis rate. 4. Management Oversight: The Controller's Office will establish a periodic review process to ensure the de minimis indirect cost rate is applied consistently, calculations are accurate, and adequate supporting documentation is maintained. Any discrepancies identified during the review process will be addressed timely to ensure compliance with Uniform Guidance requirements related to Indirect Cost Recovery.

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1241679 2025-001
    Material Weakness Repeat
  • 1241680 2025-001
    Material Weakness Repeat
  • 1241681 2025-001
    Material Weakness Repeat
  • 1241682 2025-001
    Material Weakness Repeat
  • 1241683 2025-001
    Material Weakness Repeat
  • 1241684 2025-001
    Material Weakness Repeat
  • 1241685 2025-001
    Material Weakness Repeat
  • 1241686 2025-001
    Material Weakness Repeat
  • 1241687 2025-001
    Material Weakness Repeat
  • 1241688 2025-001
    Material Weakness Repeat
  • 1241689 2025-002
    Material Weakness Repeat
  • 1241690 2025-002
    Material Weakness Repeat
  • 1241691 2025-002
    Material Weakness Repeat
  • 1241692 2025-002
    Material Weakness Repeat
  • 1241693 2025-002
    Material Weakness Repeat
  • 1241694 2025-002
    Material Weakness Repeat
  • 1241695 2025-002
    Material Weakness Repeat
  • 1241696 2025-002
    Material Weakness Repeat
  • 1241697 2025-002
    Material Weakness Repeat
  • 1241698 2025-002
    Material Weakness Repeat
  • 1241699 2025-002
    Material Weakness Repeat
  • 1241700 2025-002
    Material Weakness Repeat
  • 1241701 2025-002
    Material Weakness Repeat
  • 1241702 2025-002
    Material Weakness Repeat
  • 1241703 2025-002
    Material Weakness Repeat
  • 1241704 2025-002
    Material Weakness Repeat
  • 1241705 2025-003
    Material Weakness Repeat
  • 1241706 2025-003
    Material Weakness Repeat
  • 1241707 2025-003
    Material Weakness Repeat
  • 1241708 2025-003
    Material Weakness Repeat
  • 1241709 2025-003
    Material Weakness Repeat
  • 1241710 2025-003
    Material Weakness Repeat
  • 1241711 2025-003
    Material Weakness Repeat
  • 1241712 2025-003
    Material Weakness Repeat
  • 1241713 2025-003
    Material Weakness Repeat
  • 1241714 2025-003
    Material Weakness Repeat
  • 1241715 2025-004
    Material Weakness Repeat
  • 1241716 2025-004
    Material Weakness Repeat
  • 1241717 2025-004
    Material Weakness Repeat
  • 1241718 2025-004
    Material Weakness Repeat
  • 1241720 2025-005
    Material Weakness Repeat
  • 1241721 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
97.024 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $5.26M
97.106 SECURING THE CITIES PROGRAM $3.58M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $2.65M
66.458 CLEAN WATER STATE REVOLVING FUND $2.56M
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $1.66M
20.507 FEDERAL TRANSIT FORMULA GRANTS $1.43M
16.753 CONGRESSIONALLY RECOMMENDED AWARDS $1.35M
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $1.05M
20.933 NATIONAL INFRASTRUCTURE INVESTMENTS $907,638
66.460 NONPOINT SOURCE IMPLEMENTATION GRANTS $360,948
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $331,751
66.818 BROWNFIELDS MULTIPURPOSE, ASSESSMENT, REVOLVING LOAN FUND, AND CLEANUP COOPERATIVE AGREEMENTS $315,547
16.833 EQUITABLE SHARING PROGRAM $311,575
17.277 WIOA NATIONAL DISLOCATED WORKER GRANTS / WIA NATIONAL EMERGENCY GRANTS $233,374
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $220,948
97.039 HAZARD MITIGATION GRANT $215,556
14.856 LOWER INCOME HOUSING ASSISTANCE PROGRAM SECTION 8 MODERATE REHABILITATION $189,834
97.141 SHELTER AND SERVICES PROGRAM $173,421
10.558 CHILD AND ADULT CARE FOOD PROGRAM $169,469
16.822 NATIONAL SEXUAL ASSAULT KIT INITIATIVE $163,839
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $139,187
20.616 NATIONAL PRIORITY SAFETY PROGRAMS $138,838
16.575 CRIME VICTIM ASSISTANCE $82,840
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $73,922
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $73,513
10.675 URBAN AND COMMUNITY FORESTRY PROGRAM $64,246
14.889 CHOICE NEIGHBORHOODS IMPLEMENTATION GRANTS $45,268
17.258 WIOA ADULT PROGRAM $41,415
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $28,859
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $19,031
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $16,613
17.259 WIOA YOUTH ACTIVITIES $11,926
14.913 HEALTHY HOMES PRODUCTION PROGRAM $2,553
14.900 LEAD HAZARD REDUCTION GRANT PROGRAM $770
97.044 ASSISTANCE TO FIREFIGHTERS GRANT $144