Finding 23646 (2022-003)

Significant Deficiency
Requirement
C
Questioned Costs
$1
Year
2022
Accepted
2023-03-29
Audit: 19755
Organization: San Diego Blood Bank (CA)

AI Summary

  • Core Issue: Rental costs of $96,000 were incorrectly included in the Modified Total Direct Costs (MTDC) calculation, violating federal regulations.
  • Impacted Requirements: Compliance with 200 CFR 200.68, which mandates exclusion of rental costs from MTDC for indirect cost calculations.
  • Recommended Follow-Up: Implement procedures to ensure only allowable costs are included in MTDC calculations to prevent future noncompliance.

Finding Text

2022-003 ? Indirect Costs Based on Modified Total Direct Costs Federal Agency: Department of Health and Human Services Federal Program: Research and Development Cluster Assistance Listing Number: 93.310 ? Trans-NIH Research Support Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: According to Code of Federal Regulations, 200 CFR 200.68, the recipient must exclude rental costs from the Modified Total Direct Costs (MTDC) subject to the indirect cost rate. Condition: $96,000 rent ($8,000 a month) was included in the MTDC calculation subject the indirect cost rate. Upon testing three of the 12 monthly invoices, we further confirmed all 12 invoices included the rental costs. Questioned Costs: $9,600 (known) Context: $96,000 rent ($8,000 a month) was included in the MTDC calculation subject the indirect cost rate. Cause: MTDC calculation did not exclude rental costs. Effect: The condition identified led to noncompliance with respect to reimbursement of the rent at the 10% de minimis indirect cost rate. Repeat Finding: No Recommendation: We recommend the Blood Bank implement procedures to ensure only allowable charges outlined within 200 CFR 200.68 are included in the MTDC subject to the indirect cost rate. Views of Responsible Officials and Planned Corrective Actions Please refer to the attached Corrective Action Plan.

Corrective Action Plan

2022-003 Research and Development Cluster ? Assistance Listing No. 93.310 Recommendation: We recommend the Blood Bank implement procedures to ensure only allowable charges outlined within 200 CFR 200.68 are included in the Modified Total Direct Costs (MTDC) subject to the indirect cost rate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Blood Bank added review and approval processes to ensure only allowable charges are included in the MTDC subject to the indirect cost rate. Names of the contact persons responsible for corrective action: Bryan Eleazar, CFO; Lisa Alexander, Direct of Grant Accounting; Jeanette Lysse, Controller Planned completion date for corrective action plan: October 29, 2021

Categories

Questioned Costs Cash Management Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 23645 2022-002
    Significant Deficiency Repeat
  • 600087 2022-002
    Significant Deficiency Repeat
  • 600088 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.310 Trans-Nih Research Support $1.35M